Long-Term Modernization of Medicaid Redeterminations of Eligibility: An Analysis of State and Federal Public Policy Solutions

The negative economic effects of the COVID-19 Pandemic coupled with a state requirement for continuous enrollee coverage through the duration of the Public Health Emergency (PHE) have caused Medicaid program enrollment to swell to record levels. When states are permitted to restart Medicaid redeterminations of eligibility at the conclusion of the PHE, most enrollees will need to renew coverage, and estimates place up to 15 million at risk of coverage loss. Over the course of the pandemic, many Medicaid program enrollees experienced a positive change in income, and thus are no longer eligible for coverage. However, millions more will be at risk for improper coverage terminations due to state procedural and administrative factors, including current staffing issues and rushed processes. Medicaid is jointly run by states and the Federal Government, and states have struggled to successfully implement the provisions related to streamlining and modernizing redeterminations procedures mandated by the Patient Protection and Affordable Care Act of 2010. Because of these struggles and other state barriers to redeterminations, Medicaid enrollees have traditionally faced an uphill battle to renew coverage. Renewal difficulties disproportionately affect Black and Latino populations, causing coverage loss known as “churn” and decreasing access to care. Federal and state policymakers should consider policy implementations to mitigate the negative public health effects of churn caused by the redeterminations process. One approach could be the adoption of a state facilitated enrollment and renewal program via a CMS demonstration waiver, partnering Managed Care Organizations with states to support enrollee outreach and information gathering efforts. A second option could involve state data infrastructure enhancements and adherence to best practices to improve initial enrollee eligibility verifications known as “ex parte” reviews. Finally, states should implement CMS-proposed policy and operational strategies to ensure streamlined renewals. Policymakers should be aware of unique state redeterminations procedures and recognize the political willingness of states to adopt improvements designed to coverage retention. The PHE “unwinding” presents an opportunity of public health significance to solve long-standing Medicaid redeterminations process issues and thus address key disparities in access to affordable preventative care and chronic condition treatment for America’s most vulnerable individuals