States Plan Various Continuity of Coverage Strategies Post-PHE

March 22, 2023 - States are responding to the public health emergency unwinding in a variety of ways, with some states placing greater emphasis on continuity of coverage than others, a Kaiser Family Foundation (KFF) survey predicted.

“Some states are prioritizing maintaining coverage by implementing the unwinding more slowly and taking steps to make it easier for people to renew coverage, while others are emphasizing a quicker end to continuous enrollment that reduces budgetary costs,” the survey began.

States’ strategies can be divided into four categories: renewal streamlining, outreach to enrollees, transparency, and eligibility.

As part of streamlining renewals, the most widely-adopted approach was to take at least twelve months to complete renewals. Some states started processing renewals early, while others planned to wait until April. Out of the 49 states that responded to the survey, 43 planned to take a year or more to complete renewals.

“Taking more time to initiate and complete the unwinding process can help to avoid overwhelming staff resources and prevent inappropriate terminations but could maintain enrollment for potentially ineligible people for longer,” the researchers explained.

Thirty states intended to improve ex parte renewal rates in order to streamline renewals. Another 30 states indicated that they would automate the ex parte renewal process. Eighteen states were aiming for an ex parte renewal rate of over 50 percent.

When conducting outreach, 40 states planned to find other ways to connect with beneficiaries if their mail notifying them about Medicaid renewals got returned. States also shared that they would engage with beneficiaries who needed to go through the renewal process (36 states).  Most states will connect with beneficiaries by mail, but 24 states will respond by text message.

Another major way that states planned to support the renewal process was by adopting Medicaid expansion, an eligibility approach. Forty states said that they would use Medicaid expansion to smooth the reinitiating of the Medicaid renewal process. Additionally, 37 states reported that they would adopt 12 months of postpartum coverage.

Meanwhile, over half of the respondents planned to extend continuous eligibility for children. Twenty-six states said that they would allow continuous coverage for children in Medicaid and Children’s Health Insurance Program (CHIP) for a year.

Some states said that they would pursue better transparency to support the renewal process. Specifically, 23 states intend to publish unwinding data. Another 22 states have not yet decided whether to publish unwinding data.

Medicaid programs cannot do the renewal process alone. Most states planned to work with managed care organizations.

“States are moving from planning for the end of the continuous enrollment provision to implementation of their unwinding plans, but the impact of the unwinding will vary by state,” the researchers concluded.

“How the unwinding impacts Medicaid enrollees and state budgets will vary significantly from state to state depending on each state’s systems capabilities, including ex parte renewal rates; communications strategies; staff capacity; and adoption of operational policies that make it easier for people to stay enrolled.”

More than six out of ten adults who were enrolled in Medicaid or whose family members were enrolled in Medicaid were unaware of Medicaid renewals, a separate brief from Urban Institute indicated.

Many Medicaid programs are scrambling to prepare for the re-initiation of complex processes while also trying to mitigate the effects on enrollment.