HomeInsurance GuideWhere Medicaid unwinding and disenrollments stand at the one-year mark – Technologist

Where Medicaid unwinding and disenrollments stand at the one-year mark – Technologist

May 25, 2024

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In early 2023, states began the process of redetermining eligibility for the approximately 94 million people who were enrolled in Medicaid/CHIP at that point. Roughly a year into the process, disenrollments appear to be on track to be higher than projected.

Here’s a look at what’s been happening with disenrollments – and also a look at the beneficiaries who have had their Medicaid coverage renewed during the process.

The Medicaid unwinding process

Medicaid disenrollments had been paused for three years due to the COVID-19 pandemic, so coverage was continuous, regardless of whether people continued to meet the eligibility guidelines. Enrollment had grown by more than 22 million people during that time.

Under the “unwinding” of the pandemic-era continuous coverage rule, states could begin to disenroll people from Medicaid as early as April 1, 2023, although most states waited until May, June, or July.

National disenrollment totals at a glance

Here’s a look at disenrollment totals and at Medicaid/CHIP total enrollment:

  • By December 2023, nine months after the end of the ban on disenrollments, total Medicaid/CHIP enrollment had dropped from approximately 94 million to approximately 85 million people. There are a few months of lag in federal data reporting, but many states are posting more recent numbers in their enrollment and unwinding dashboards.
  • KFF has been compiling this data throughout the unwinding process and reported that more than 20.1 million people had been disenrolled from Medicaid/CHIP as of April 11, 2024. But KFF noted that was an undercount, as some states have a lag in their data reporting.
  • Georgetown University’s Center for Children and Families has been tracking net Medicaid/CHIP enrollment – accounting for both disenrollments and new enrollments – and found that as of April 2024, the Medicaid population had declined by almost 11.8 million people. Like KFF, the center noted that data was not entirely up to date due to the reporting lag in some states.

Disenrollments will likely be higher than projected

In 2022, the Department of Health and Human Services (HHS) projected that about 15 million people would be disenrolled during the year-long unwinding process. Other projections had been similar but a little higher: KFF had projected 17 million disenrollments, and the Urban Institute had projected about 18 million disenrollments.

Given that there were already more than 20 million disenrollments as of April 2024 – with a reporting lag in some states and several months to go in the unwinding process in many states – it certainly looks like the total number of disenrollments will ultimately be higher than the projections once the unwinding is complete.

But net Medicaid/CHIP enrollment will likely remain higher than it was pre-pandemic. Some people disenrolled from Medicaid during the unwinding process have since re-enrolled, as shown in Idaho. And several states have expanded Medicaid in the last few years, resulting in more people becoming eligible for coverage:

  • Utah and Idaho expanded Medicaid in January 2020, just as the pandemic was beginning.
  • Oklahoma expanded Medicaid in July 2021
  • Missouri expanded Medicaid in October 2021
  • South Dakota expanded Medicaid in July 2023
  • North Carolina expanded Medicaid in December 2023

Medicaid enrollment is open year-round, so even in states where the eligibility guidelines have not changed, there have been new enrollments alongside the disenrollments. The influx of new enrollees over the last year – including some who were disenrolled and then re-enrolled or had their coverage reinstated – is why net enrollment is only down about 11.8 million people, even though 20.1 million people have been disenrolled.

How many people have had their Medicaid renewed?

By April 2024, eligibility redeterminations had been completed for nearly 64 million people. (Again, that’s an undercount due to reporting lags in many states.) The majority – 43.6 million people – were found to still be eligible and their coverage was renewed.

Of those renewals, 59% were completed on an ex parte basis, meaning the state was able to determine the person’s eligibility based on existing data, without needing the enrollee to submit any additional information. The other 41% submitted their completed renewal paperwork and were found to still be eligible.

States are required to attempt ex parte renewals before sending an enrollee a renewal packet. But there has been a great deal of variation from one state to another: Ex parte renewals account for 99% of North Carolina’s renewals, but only 8% of Pennsylvania’s. The variation is due to a variety of factors, including the data sources that states use, the process a state has in place for managing data from multiple sources, and whether a state has protocols in place to use the ex parte process when a person’s eligibility is based on both income and assets, rather than just income.

The ex parte renewal rate has increased over time during the unwinding period. In April 2023, only about 25% of redeterminations were completed with the ex parte process. By December 2023, that had grown to about 47%.

Why have states disenrolled Medicaid beneficiaries?

Of the 20.1 million disenrollments, only about 31% were determined ineligible. The majority – about 69% – were terminated for procedural reasons, meaning the state didn’t have enough information to determine whether they were still eligible.

Although the majority of all disenrollments nationwide have been procedural, there’s significant variation from one state to another: In Nevada and New Mexico, 93% of all disenrollments have been procedural, while only 22% of Maine’s disenrollments have been procedural (Maine paused procedural disenrollments in August 2023 and does not plan to resume them until mid-2024).

Procedural disenrollments can happen for a variety of reasons. In some cases, the person may have already enrolled in new coverage and chose to ignore the Medicaid renewal because they no longer need the coverage. But we also know that some beneficiaries lost eligibility due to procedural disenrollments – even though they may still meet the eligibility guidelines – because they didn’t receive their renewal packets or didn’t understand what they needed to do to keep their coverage.

What should I do if I’ve been procedurally disenrolled?

If a person’s coverage is terminated for procedural reasons, the state must allow them at least a 90-day window during which they can submit a renewal form and have their eligibility reconsidered without having to start over with a new application.

We have only limited data on how many procedurally disenrolled people have had their coverage reinstated during the reconsideration window, as most states are not reporting this.

But regardless of where you live, the reconsideration window is available. If your coverage was terminated because you didn’t complete the renewal process, you have at least 90 days during which your eligibility can be redetermined if you submit the renewal form.

Even if you miss that deadline, you can submit a new application for Medicaid/CHIP at any time. So if your coverage has been terminated and you think you might still be eligible, your first step should be submitting your renewal paperwork, or a new application if you miss the 90-day renewal submission window.

What should I do if I’m no longer eligible for Medicaid?

If you’ve lost your Medicaid/CHIP coverage because you’re no longer eligible – and you’re certain that the state has correctly deemed you ineligible and didn’t procedurally disenroll you due to lack of information – you may find that you can enroll in new coverage right now, even if it’s been several months since you lost your Medicaid coverage.

Loss of Medicaid/CHIP is a qualifying life event that triggers a special enrollment period. This allows people to enroll in a plan in the individual/family market or a plan offered by an employer, if available. Here’s what you need to know about the timing and the financial assistance that’s available, if eligible:

  • If you’re eligible for an employer’s plan, you must submit your enrollment within 60 days of the loss of your Medicaid coverage. Otherwise, you’ll need to wait until the employer’s next annual open enrollment period.
  • If you’re not eligible for an employer’s plan, an individual/family health plan obtained through the health insurance Marketplace (exchange) might be a good option. Most people who enroll in Marketplace coverage are eligible for financial assistance. Across all Marketplace enrollees who selected plans during the open enrollment period for 2024 coverage, 92% were receiving premium tax credits and nearly 50%were receiving cost-sharing reductions.
  • The length of time you have to enroll in an individual/family plan will depend on where you live and whether you’re enrolling through the Marketplace or off-exchange (directly through an insurer).
    • In states that use HealthCare.gov as their Marketplace, enrollment in the Marketplace is open through November 30, 2024 for anyone who loses Medicaid between March 31, 2023 and November 30, 2024. So even if you lost your Medicaid several months ago, you can sign up for new coverage now.
    • In states that run their own Marketplace, the special enrollment period due to loss of Medicaid/CHIP has to continue for at least 60 days after the loss of Medicaid. But these states have the option to make this window longer, including offering the extended special enrollment period (SEP) that’s available on HealthCare.gov. Check with your state’s Marketplace for more information.
    • After November 2024, HealthCare.gov will offer a SEP that continues for 90 days after the loss of Medicaid/CHIP. State-run Marketplaces have the option to offer this extended SEP (or an even longer one) or to continue to limit the SEP to 60 days.
    • If you’re enrolling off-Marketplace, the SEP will generally only continue for 60 days after your Medicaid coverage ends. But most people choose to enroll through the Marketplace, as that’s the only way to obtain financial assistance if you are eligible.

How many people have transitioned from Medicaid to Marketplace plans?

The Centers for Medicare & Medicaid Services (CMS) are reporting data on the number of people who have transitioned from Medicaid to a Marketplace plan. (See data for states that use HealthCare.gov and for states that operate their own exchange.)

Through December 2023, more than 3.4 million people had transitioned from Medicaid/CHIP to a private qualified health plan in the Marketplace, and another 257,116 had transitioned to a Basic Health Program (currently only available in New York and Minnesota).

There is some lag in the data reporting, but millions of people who previously had Medicaid/CHIP had transitioned to a Marketplace plan during the first several months of the unwinding process.

If you’ve lost or will soon lose Medicaid or CHIP coverage and you’re not eligible to enroll in employer-sponsored coverage, a Marketplace plan could be a good option. It’s certainly worth your time to explore the available plans and understand the financial assistance that may be available to you through the Marketplace.

Louise Norris is an individual health insurance broker who has been writing about health insurance and health reform since 2006. She has written dozens of opinions and educational pieces about the Affordable Care Act for healthinsurance.org.

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