On April 4, 2022, the Centers for Medicare and Medicaid Services (CMS) published two new resources addressing Medicaid’s Public Health Emergency (PHE) “unwinding” activities.[i] Today’s post focuses on CMS’ summary of promising state practices for unwinding planning efforts.
While CMS cites some state-specific examples, at this time the agency generally does not list state-by-state strategies or approaches being contemplated.[ii] Separate from the April 4 resources, CMS previously announced it was requiring all states to submit a plan describing how they intend to distribute renewals as well as the processes and strategies each state is considering, or has adopted, to mitigate against inappropriate coverage loss during the unwinding period.[iii] CMS has not indicated whether it intends to publish all or parts of these submissions.
The April 4 summary of promising practices provides helpful insights that can support states that are continuing to solidify their plans as well as health plans, providers, and other stakeholders engaged in preparing for the end of Medicaid’s continuous coverage requirement.
Experts from across HMA reviewed this document for insights to support our work with states, health plans, providers, and other key stakeholders. Jane Longo, Andrea Maresca, and Bill Snyder offer the major takeaways below.
Medicaid and CHIP Unwinding Planning Efforts
The CMS best practices document identifies four themes based on the federal agency’s ongoing discussions with states:
- Renewals and Redeterminations – Key Findings
- Updating Enrollee Contact Information
- Workforce Capacity
- Outreach, Partnerships, & Communications
HMA’s Top Five Takeaways
- CMS reported that over half of states have attempted to process full renewals where possible (via ex parte and by sending and processing renewal forms). However, several states have not conducted any renewals during the PHE. States also reported wide variation in ex parte renewal success rates, and many noted that rates have declined as the PHE has progressed.
- Takeaway: States that have not processed full renewals likely may experience more capacity challenges as they seek to review and prioritize renewals for the larger caseload that has built up during the time period for the continuous coverage requirement. Further, the declining success with ex parte renewals signals those states may not be able to rely upon this process as extensively as initially expected. As a result, states – and stakeholders – will need to adjust their outreach and capacity planning accordingly to reflect the need for more engagement and follow-up with individuals. Stakeholders in these states should consider the impact of activating additional capacity to support individuals with the eligibility process.
- According to CMS, “many” states are planning to take a population-based approach to prioritize redeterminations for individuals most likely to be ineligible for Medicaid/CHIP.
- Takeaway: States that are flagging beneficiaries whose coverage could not be renewed during the PHE (due to ineligibility or non-response to information requests) will be able to support a population-based approach to renewals and redeterminations. This approach could help extend enrollment for individuals who are most likely to remain eligible for Medicaid. States and stakeholders should undertake capacity planning that reflects the potential for uneven distribution of workload with this approach, including outreach and enrollment assistance, during the 12-month unwinding period and beyond.
- Enrollee contact information: Regarding contact information, CMS reported that, “More than half of states are working with managed care organizations on contact information updates.”
- Takeaway: This indicates there is significantly more planning and engagement that needs to occur with Medicaid health plans. Health plans, providers, community-based organizations and others should be developing outreach and assistance plans. They may also want to collaborate and engage the state around these collective efforts.
- Workforce capacity: Most states told CMS that workforce capacity is a top concern. The document lists several strategies states are implementing.
- Takeaway: Constraints on workforce capacity could complicate implementation of state plans, regardless of how long a state is planning to take to resume normal operations and complete the renewal and redetermination work. This information may inform federal and state level advocacy efforts, especially for stakeholders who continue to seek additional resources, time, and other statutory or regulatory changes to ease the transition from the continuous coverage requirement.
- State outreach and partnerships: CMS reports that states have begun to think about outreach and enrollee communications strategies for the Medicaid unwinding.
- Takeaway: While states have begun to consider their strategies, many states have not launched the full scope of planned efforts because they are waiting for more certainty of the PHE’s end date. This may be a reasonable approach, particularly if there is a need to preserve resources and maximize response from Medicaid enrollees at the right point in time. However, stakeholders can take certain steps now and should be developing their outreach and assistance plans for the unwinding work that is imminent. Early planning may also help mitigate some of the workforce capacity challenges that are anticipated once eligibility processes resume.
The U.S. Department of Health and Human Services (HHS) is widely expected to renew the COVID-19 PHE declaration before it expires on April 16, 2022. If extended in April for the full 90 days permitted, the next PHE declaration would expire July 15, 2022. There is more uncertainty surrounding additional extensions beyond July, and states and stakeholders should be considering this timeframe in their planning efforts.
HMA is supporting states and stakeholders with planning and implementation efforts for these Medicaid unwinding efforts. More information is available here:
How stakeholders can prepare now for unwinding of Medicaid public health emergency continuous eligibility
Ending Medicaid Continuous Eligibility – What Stakeholders Can Do Now to Minimize Coverage Losses (Webinar Replay)
Learning from COVID-19-related flexibilities: moving toward more person-centered Medicare and Medicaid programs
[i] CMS’ April 4, 2022 tools include: Medicaid and CHIP Unwinding Planning Efforts: Summary of Best & Promising State Practices from CMS/State Discussions and Strategic Approaches to Support State Fair Hearings as States Resume Normal Eligibility and Enrollment Operations After the COVID-19 PHE
The full list of CMS resources is posted on the Medicaid.gov website, “Unwinding and Returning to Regular Operations after COVID-19,” Accessed April 4, 2022: https://www.medicaid.gov/resources-for-states/coronavirus-disease-2019-covid-19/unwinding-and-returning-regular-operations-after-covid-19/index.html
[ii] The Kaiser Family Foundation published a report based on a survey in the field in January 2022. This was before CMS published more detailed information on states’ plans. See “Medicaid and CHIP Eligibility and Enrollment Policies as of January 2022: Findings from a 50-State Survey:” https://www.kff.org/medicaid/report/medicaid-and-chip-eligibility-and-enrollment-policies-as-of-january-2022-findings-from-a-50-state-survey/
[iii] CMS State Reporting resource, “State Report on Plans for Prioritizing and Distributing Renewals Following the End of the Medicaid Continuous Enrollment Provisions.”