The CMS is cracking down on states that aren’t complying with federal requirements during Medicaid redeterminations, in a bid to curb procedural disenrollments.
Since April, the CMS has worked with 12 states to pause terminations to address issues related to compliance with renewal requirements, according to a spokesperson.
Concerns over the high number of procedural disenrollments, when people lose Medicaid coverage due to administrative or paperwork errors but might still be eligible, have dogged the redeterminations process.
Overall, an estimated 3 million people have been disenrolled since redeterminations started in April, according to KFF.
Across states that report such data, three-fourths of all people disenrolled lost coverage due to procedural reasons.
“We are concerned, in particular, the majority of people that have lost coverage have lost coverage for what we call procedural reasons,” said Dan Tsai, director of the Center for Medicaid and CHIP Services, during a Wednesday media briefing. “We are using every lever that Congress has given us to hold states accountable to following all the federal requirements with Medicaid renewals.”
When the CMS identifies issues with a state’s redeterminations process, it requires states to pause eligibility checks and reinstate any enrollees that were improperly terminated. Redeterminations remain on hold — either for an individual or on a larger basis — until states fix the problem.
In some states, “tens of thousands” of people have been reinstated to Medicaid rolls following CMS intervention, Tsai said.
A significant amount of money is on the line. Enhanced federal funding for state Medicaid programs is tied explicitly to states following all federal requirements in the redeterminations process, Tsai said.
So far, states have immediately moved to resolve any violations, and CMS hasn’t issued corrective action plans.
The CMS declined to specify which states that have been noncompliant, but regulators are currently in discussions with roughly a dozen other states to assess potential violations of a federal redeterminations requirement, according to Tsai.
The agency has run into a number of violations with states not following the required regulatory process, officials said on the call. For example, states are required by regulation to auto-renew individuals if the state can verify their income information, but in some cases system glitches have prevented electronic data matching.
Researchers and regulators are still determining the effect that Medicaid eligibility checks are having on the coverage landscape, given it’s early in the process and states are reporting varying data.
CMS plans to release aggregate and state-level redeterminations data in the next few weeks, according to Tsai. But current CMS estimates say 45% of members are being renewed in Medicaid, while roughly a third are disenrolled.
Regulators are particularly concerned about coverage in states that have yet to expand Medicaid to a greater share of low-income individuals, resulting a coverage gap. However, the CMS is already seeing an increase in Healthcare.gov call center volume, suggesting ex-Medicaid members are turning to Affordable Care Act plans, CMS Administrator Chiquita Brooks-LaSure said on the Wednesday call.
Earlier this year, the CMS released policy flexibility to help states curb procedural disenrollments, include allowing managed care plans to help beneficiaries complete their renewal forms. States taking up these waivers should help reduce the terminations, regulators said.
Ten states have elected to adopt a new CMS option to delay procedural terminations for at least a month to conduct outreach, according to the agency spokesperson.
Of all U.S. states, just Florida and Montana have yet to pick up a waiver, according to Tsai. The Medicaid head noted the CMS is in talks with Montana on what waivers might make sense for the state.