Medicaid Eligibility in Jeopardy

Medicaid program members are losing benefits in record numbers in wake of COVID-19 PHE

More than a half million people in 12 states have been disenrolled from Medicaid since March 31.

What we don’t know, however, is how many of those individuals still qualify for care and services and got caught up in administrative shuffling following the unwinding of the pandemic-era continuous enrollment provision.

And, since that disenrollment number comes from data collected from only a handful of states, the actual number of individuals who have lost Medicaid benefits since March is likely much greater.

Throughout the COVID-19 public health emergency (PHE), the federal government maintained a continuous enrollment provision for Medicaid programs. This meant those who qualified for Medicaid benefits while the provision was in effect could not lose access, regardless of eligibility status. While the provision remained in effect, the number of Medicaid and Children’s Health Insurance Program (CHIP) members reached more than 90 million nationwide.

Unfortunately, according to survey data from the Kaiser Family Foundation (KFF), many of the individuals who have already lost coverage due to procedural issues should still qualify for care and services. Their disability status and/or income has not changed, and their disenrollment was the result of an administrative and procedure issue, not an eligibility determination.

So far, the picture of the impact of the unwinding of the continuous enrollment provision is incomplete. Most states have not released any enrollment data publicly since disenrollment activities could resume. Additionally, the data points collected and published by states are not consistent from state to state.

Still, the limited information available gives us some key takeaways from the first couple of months following the end of the continuous enrollment provision, including:

• Many disenrolled members still qualify for Medicaid benefits.
• Higher early disenrollment rates are in states where renewal requests were sent to program members while the PHE was in effect.
• Nearly two-thirds of Medicaid program members are not aware there is no longer a continuous enrollment provision protecting their eligibility.

Procedural hiccups have caused a number of Medicaid beneficiaries to lose access to coverage as disenrollment has resumed, according to the KFF report. According to the organization, nearly two-thirds of current Medicaid enrollees say they have not had a change in income or circumstance in the last year that would impact their eligibility. If they were to be caught up in the mass disenrollment occurring now, these individuals may not be able to afford vital care and services they need every day.

The number of “procedural terminations” is hard to determine without timely and consistent data from states, according to a Health Management Associates analysis. “As Medicaid stakeholders know, the procedural disenrollment number is critical because these individuals could still be eligible for the program,” HMA noted in a recent report.

According to the KFF, the states that sent renewal requests before the provision was lifted have seen greater early disenrollment rates because as a first step, they have automatically removed any program member who did not respond to a request for renewal. Even during normal times, re-enrollment can be challenging for aging and disabled populations given the complexities of paperwork or inability to complete enrollment tasks without assistance. Other states, according to the data collected, are determining future eligibility at the time of each program member’s scheduled renewal, so initial disenrollment numbers may not be as high.

Finally, in preparation for the end of the continuous enrollment provision, many states sent out information and reminders to current program members about the potential for losing access to benefits this spring and summer. KFF now argues more outreach needs to be done to protect members from procedural disenrollment as too many are still unaware of the potential loss in coverage.