September 21 – The Centers for Medicare & Medicaid Services (CMS) released a list of 29 states plus the District of Columbia that to date have self-identified as erroneously making ex parte renewal decisions on a household level, rather than an individual level as federal regulations require. Ex parte renewals use already available data, reducing burdens on enrollees; in its materials CMS characterizes ex parte renewals as “one of the strongest tools that states have to keep eligible people enrolled in Medicaid or CHIP [Children’s Health Insurance Program] coverage during the renewals process.”
CMS identified this issue in late August, which we now know led to nearly half a million children and other individuals losing coverage. CMS directed states to report by September 13 on whether they had this issue and, if so, the steps the state would take to address it. CMS set out steps that impacted states must take to pause procedural terminations, reinstate coverage, implement mitigation strategies, and fix their systems and processes.
Key takeaways from the information posted by CMS include:
- To date, 29 states and D.C. self-identified as having the issue; others are continuing to assess their systems and whether people erroneously lost coverage.
- States will reinstate coverage for nearly 500,000 children and other individuals who were improperly disenrolled from Medicaid or CHIP.
- CMS is requiring these states to pause procedural disenrollments for impacted people, unless the state can ensure all eligible people are not being improperly disenrolled due to this issue.
- CMS will offer direct assistance as states work to complete their assessments and achieve compliance.
CMS’ decision to post this information shortly after it received it from states is a key step to holding states accountable for addressing the issue, which they are starting to do by reinstating coverage for impacted people. For example, last week Nevada announced that it had reinstated eligibility for 130,000 people.
Transparency will also help stakeholders across the country raise awareness among people who erroneously lost coverage and help make sure they know their coverage was reinstated.