Over 9 million Medicaid beneficiaries disenrolled as redeterminations continue

Medicaid disenrollments resumed several months ago (in April, May, June, or July, depending on the state), and the process is proceeding mostly as expected, with millions already disenrolled. But it’s also had some unexpected problems.

Here’s a look at disenrollments thus far – and a look at who’s been losing Medicaid coverage, and how some who’ve been disenrolled are taking steps to replace their lost coverage.

How many people have been disenrolled from Medicaid?

As of October 19, more than 9 million people had been disenrolled from Medicaid¹ as a result of states resuming disenrollments after the pandemic-era federal continuous coverage requirement ended in the spring of 2023.

Eligibility redeterminations – also known as renewals — must be conducted for all Medicaid enrollees during a year-long “unwinding” period. And the disenrollments were not unexpected; HHS had projected that approximately 15 million people would be disenrolled from Medicaid during the unwinding of the pandemic-era continuous coverage rules.²

States had the option to prioritize eligibility redeterminations for enrollees they believed were most likely to no longer be eligible,³ so it’s not surprising that there was a fairly high rate of disenrollments in some states in the early months of the unwinding process. For example, by September (last month), Idaho had already completed eligibility redeterminations for everyone whose eligibility had been pending during the pandemic, and is now back to their normal annual eligibility redeterminations.⁴

Most disenrollments due to procedural reasons

What may be surprising is that nearly three-quarters of the disenrollments have been for procedural reasons,⁵ meaning that a state was unable to determine whether someone who had Medicaid coverage was still eligible. This problem can happen because a Medicaid office doesn’t have a beneficiary’s current contact information.

In some cases, a beneficiary received a renewal packet but hasn’t submitted the information the state needs to process the renewal. This could be because the person knows they’re no longer eligible and may have already enrolled in other coverage (such as a plan offered by a new employer). But in other cases, the beneficiary might not understand what’s required in order to complete the renewal, or may have simply fallen behind on dealing with paperwork.

CMS pauses procedural enrollments in 29 states and DC

In late August 2023, the Centers for Medicare and Medicaid Services (CMS) addressed the fact that numerous states had problematic renewal protocols involving households where some members were eligible for ex parte (automatic) renewals and others were not.⁶ In many states, renewal paperwork was being sent to the household, and if it wasn’t completed, the entire household was being disenrolled, including household members (often children) who were eligible for ex parte renewal.

Twenty-nine states and the District of Columbia have had to pause procedural disenrollments⁷ until they can confirm that individuals who are eligible for Medicaid or CHIP (Children’s Health Insurance Program) are not being disenrolled due to eligibility redeterminations being conducted at the household (rather than individual) level. And CMS directed states to reinstate coverage for nearly 500,000 people – many of whom are children – whose coverage had been incorrectly terminated due to this issue.⁸

CMS had previously directed some states to pause procedural disenrollments while problems with their eligibility redetermination processes were addressed. As of June 2023, some or all procedural disenrollments had been paused in DC and 16 states.⁹

A pause on procedural disenrollments does not prevent a state from continuing to process renewals and disenroll people who no longer meet the eligibility guidelines. It just prevents states from disenrolling people when they don’t have enough information to determine whether the person is still eligible.

And states can adjust their approach to processing Medicaid redeterminations based on state-specific circumstances. For example, Hawaii opted to pause all Medicaid disenrollments through the end of 2023¹⁰ due to the wildfires in Maui, and will wait until June 2024 to resume eligibility redeterminations for West Maui residents.¹¹

How many people have transitioned from Medicaid to Marketplace coverage?

People who are no longer eligible for Medicaid can switch to other coverage, typically either from an employer, Medicare, or the Marketplace. (Eligibility for each type of coverage depends on the person’s specific circumstances.)

In September 2023, CMS published data on Marketplace enrollments among people who had recently been enrolled in Medicaid.¹² As of June 2023:

• More than 291,000 former Medicaid enrollees had selected Marketplace qualified health plans (QHPs) through HealthCare.gov.¹³
• More than 63,000 people had selected QHPs through state-run exchanges.¹⁴
• In addition, nearly 56,000 people had transitioned to Basic Health Program (BHP) coverage in New York and Minnesota.¹⁵

So, based on CMS’ recent reports, more than 410,000 former Medicaid enrollees had transitioned to Marketplace coverage – QHP or BHP coverage – by June 2023.

In the state-run exchanges, enrollment included nearly 7,600 people for whom a QHP had been automatically selected.¹⁴ Only four states (California, Maryland, Massachusetts, and Rhode Island) have implemented auto-enrollment protocols for at least some people whose Medicaid is terminated during the unwinding process. In the rest of the country, a person’s data may be transferred to the Marketplace, but they must actively select a plan in order to enroll in a QHP.¹⁶

Subsidies for Medicaid beneficiaries transitioning to coverage on the Marketplace

Last year, CMS had estimated that 2.7 million people losing Medicaid during the unwinding period would be eligible for advance premium tax credits (APTC) to offset the cost of Marketplace coverage.² As of June 2023, a total of about 583,000 former Medicaid enrollees had been deemed eligible for APTC (337,230 in states that use HealthCare.gov¹⁷ and 245,879 in states that run their own exchanges.¹⁸)

APTC eligibility depends on income but also on whether the person has an offer of affordable coverage from an employer. People who lose Medicaid but are eligible to enroll in an employer’s plan are generally not eligible for financial assistance in the Marketplace.

Special enrollment in the Marketplace for those disenrolled from Medicaid

It’s important to note that HealthCare.gov has an ongoing special enrollment period, through July 2024, for people who lose Medicaid during the unwinding process. So a person who lost Medicaid early in the unwinding process still has a lengthy window to enroll in a Marketplace plan if that’s their preference.

States that run their own exchanges can choose to offer extended special enrollment periods for people who lose Medicaid, or they can use the normal special enrollment period rules that allow a person up to 60 days to select a new plan after losing Medicaid.

What should current enrollees expect as Medicaid redetermination continues?

While the number of disenrollments is over 9 million, it’s important to note that the redetermination process is still ongoing. Current enrollees should keep an eye out for communications from their state’s Medicaid office, especially if their coverage hasn’t been renewed recently.

In most states, the eligibility redetermination process begins two or three months before an enrollee’s renewal date. Federal rules require states to give most Medicaid enrollees at least 30 days to return their renewal packets, but states often allow 45 days or more. (For Medicaid enrollees who are 65 or older, or who are eligible due to disability or blindness, the state must provide “a reasonable period of time.”)¹⁹

If the state is able to renew an individual’s coverage automatically, the beneficiary will simply receive a notification letting them know that their coverage has been renewed. But if not, the state will let them know what information they have to provide in order to renew coverage, along with a deadline at least 30 days out.

If a person does not submit the necessary documentation by the deadline, coverage can be terminated. However, if a beneficiary submits the renewal information no more than 90 days after the coverage was terminated, states are required to determine eligibility without requiring the person to submit a new application, and reinstate coverage if the person is eligible.²⁰

Read our overview of Medicaid redetermination to learn more about coverage replacement options for people who are disenrolled from Medicaid. The overview also links to pages devoted to each state’s Medicaid program, with details about how the unwinding process is being handled.

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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.

Footnotes

1. “Medicaid Enrollment and Unwinding Tracker” KFF.org, Oct. 19, 2023 ⤶
2. “Unwinding the Medicaid Continuous Enrollment Provision: Projected Enrollment Effects and Policy Approaches” HHS.gov, Aug. 19, 2022 ⤶ ⤶
3. “Medicaid and CHIP Unwinding Planning Efforts” Medicaid.gov, April 2022 ⤶
4. “From DHW Director Dave Jeppesen: Idaho completes Medicaid reevaluations efficiently and accurately” Idaho Department of Health and Welfare, Sept. 8, 2023 ⤶
5. “Medicaid Enrollment and Unwinding Tracker” KFF.org, Oct. 16, 2023 ⤶
6. “Requirements to Conduct Medicaid and CHIP Renewal at the Individual Level” Medicaid.gov, Aug. 30, 2023 ⤶
7. “State Compliance with Medicaid Renewal Requirements at Individual Level” Medicaid.gov, Accessed 2023 ⤶
8. “Coverage for Half a Million Children and Families Will Be Reinstated Thanks to HHS’ Swift Action” CMS.gov, Sept. 21, 2023 ⤶
9. “Medicaid and CHIP National Summary of Renewal Outcomes – June 2023 Data” Medicaid.gov, September 2023 ⤶
10. “DHS MED-QUEST PAUSED MEDICAID DISENROLLMENTS FOR 2023” Hawaii.gov, Sept. 10, 2023 ⤶
11. “MQD 092523 Updated Stats.pdf“ Hawaii.gov, Sept. 25, 2023 ⤶
12. “Monthly Data Reports“ Medicaid.gov, September 2023 ⤶
13. “gov Marketplace Medicaid Unwinding Report” HealthCare.gov, Sept. 29, 2023 ⤶
14. “State-based Marketplace (SBM) Medicaid Unwinding Report” HealthCare.gov, Sept. 29, 2023 ⤶ ⤶
15. “Affordable Care Act’s Basic Health Program” healthinsurance.org, June 26, 2023 ⤶
16. “Marketplace Enhanced Outreach for Unwinding Webinar” CMS.gov, April 10, 2023 ⤶
17. ”HealthCare.gov Marketplace Medicaid Unwinding Report” Medicaid.gov, Sept. 29, 2023 ⤶
18. ”State-based Marketplace (SBM) Medicaid Unwinding Report” Medicaid.gov, Sept. 29, 2023 ⤶
19. “Requirements to Conduct Medicaid and CHIP Renewal at the Individual Level” Medicaid.gov, Aug. 30 2023 ⤶
20. “42 CFR § 435.916 – Periodic renewal of Medicaid eligibility” Code of Federal Regulations, Accessed October 2023 ⤶