Older woman writing in journal

The Centers for Medicare & Medicaid Services this week sent a letter to state Medicaid directors addressing the “operational issues” that are kicking people off Medicaid during the federal unwinding period. These issues may come down to faulty programming in state Medicaid plans’ methods of auto-renewing enrollees, CMS said.

“CMS believes that eligibility systems in a number of states are programmed incorrectly and are conducting automatic renewals at the family-level and not the individual-level, even though individuals in a family may have different eligibility requirements to qualify for Medicaid and CHIP,” the agency said in a statement. 

Auto-renewals, or “ex parte” renewals, are “one of the strongest tools that states have to keep eligible people enrolled in Medicaid or CHIP coverage,” according to CMS. However, family-based auto-renewals might improperly disenroll some eligible individuals when their family members do not qualify for coverage. 

In response to this, CMS mandated that affected states pause procedural terminations for people improperly disenrolled by ex parte renewals, reinstate their coverage, switch auto-renewals from the family level to the individual level, and implement one or more strategies to mitigate further operational issues, according to the letter. Such strategies could include extending Medicaid eligibility for affected families up to a year after their scheduled renewal period, or another mitigation technique approved by CMS.

CMS gave states a deadline of Sept. 13 “to identify any areas of noncompliance related to the appropriate determination of eligibility for individuals in multimember households.”

CMS’ actions this week seek to mitigate flaws in a renewal process that has been present for “a very long time,” said Damon Terzaghi, Medicaid director of home- and community-based services for the National Association for Home Care & Hospice.

“I think that this will make some improvements in those states that were not performing eligibility determinations at the individual level,” he said in an email to McKnight’s Home Care Daily Pulse. “The ex parte process appears to be where most of the successful renewals are occurring, so it is likely that increasing the use of ex parte renewals will reduce disenrollments.”

The unwinding, a result of the end of COVID-19 eligibility requirements, has resulted in many states dropping Medicaid beneficiaries from their rolls, in large part due to procedural reasons. At least 3.8 million individuals have already been removed from Medicaid in the 41 states where data is available, according to a recent report from the Kaiser Family Foundation. A total of 15–20 million people are expected to lose coverage over the next 12 months. Older adults and people with disabilities are among the groups affected.

This most recent action by CMS will only affect individuals who have been improperly disenrolled by this auto-renewal process, Terzaghi noted.