How is Each State Handling Medicaid Redetermination?

Medicaid enrollment has always been governed by individual states. As we enter the Medicaid unwinding process following the public health emergency (PHE) prompted by the COVID-19 pandemic, governance remains the same. Under federal guidance from the Centers for Medicare & Medicaid Services, it’s the responsibility of each individual state to decide how it will navigate Medicaid redetermination. 

It’s critical to know what your individual state’s plan for Medicaid “unwinding” will be in order to assist your patient population and prevent unnecessary lapses in coverage. Knowing your state’s approach is what determines your role in the reenrollment process. 

General guidelines for unwinding 

Prior to the official start of Medicaid “unwinding” on April 1, 2023, CMS released general guidelines to help each state navigate the unwinding process. These guidelines included four options to approach unwinding, including population-based, time-based, hybrid and state-based. More information on these four approaches can be found here.

Each state was required to submit its finalized plan for unwinding to CMS for approval. As federal officials gathered information on what each state had planned, CMS continued to release a series of best practices and information designed to help states move forward while minimizing Medicaid “churn.”

Some of these best practices include: 

• Planned distribution & prioritization of Medicaid renewals
• Engagement strategies for “returned mail” customers without updated contact information
• Social media as a communication tool 
• Targeted outreach
• Expanding state Medicaid offices via hiring and vendor relationships to handle increased workload
• Updated systems and technologies to promote automation and efficiencies 

Why should you know what your state is doing?

Serving your patient population to the best of your ability requires an in-depth knowledge of your state’s unwinding process. The main focus throughout unwinding will surround newly enrolled Medicaid patients. 

Medicaid enrollment increased by 27% to 91 million people throughout the PHE. These newly added patients have been auto-renewed and have never experienced the renewal process. They may not even know it’s required to continue their coverage. Others may no longer be eligible for Medicaid, having aged out, gotten new insurance or reported an increase in income. 

It’s our goal as healthcare finance professionals to allocate resources appropriately by identifying patients no longer eligible for Medicaid and efficiently prioritizing renewals for those that are. The only way to meet this goal is to leverage data and technology. 

Start by collecting data on what your state is doing to facilitate the unwinding process. How are they renewing patients and what information and resources did they make available to you that you can use in your own outreach efforts? Your state may provide renewal dates for your patients in advance. With these dates in hand, you can coordinate outreach efforts and have a much better chance of reaching patients before their coverage expires.

Unfortunately, not all states are providing this type of data and are taking their own approach to renewal. In this case, education is your best tool. Take some time to understand your state’s plan and available data and resources you can leverage today. 

Examples of different state approaches

Below, we’ve examined different approaches to Medicaid unwinding from three major states: Florida, New York and California.  

‍

• New York

New York faces the challenge of determining eligibility for 8.8 million residents, including 1.4 million people who have never renewed and 7.4 million who have not renewed within the last two years. 

The state is taking a time-based approach to Medicaid unwinding, as originally outlined by CMS. Under this approach, the state will either prioritize renewing Medicaid accounts that have been due for renewal the longest (i.e. those that would have expired the fastest at the start of the PHE in March 2020) or the state can choose to keep the renewal month the same, meaning accounts due for renewal in May 2020 would simply be moved to a scheduled May 2023 renewal. 

New York has evenly distributed renewals across a 12-month period, with patients receiving renewal notices at least 60 days before coverage ends. This approach will make use of data and technology for methodical outreach on a scheduled basis. 

• Florida

Florida is taking a state-determined approach, meaning they have developed their own plan for unwinding. The plan must follow general CMS guidelines to promote retention, remove ineligible patients and plan for future renewals. 

‍

Florida has started with a sort of population-based approach, prioritizing redetermination first for individuals already identified as likely ineligible for coverage and who have not used their Medicaid benefits in over one year. Then, the state will assess populations who have used their coverage within the past year but are determined to likely be ineligible. 

‍

After conducting redetermination on these two groups, Florida will move into a more time-based approach, prioritizing renewals based on the date of the individual’s last renewal. Renewals will be spaced out over the full unwinding period to avoid overwhelm and distribute work evenly each month. 

‍

Redeterminations for vulnerable populations, including those on hospice care, those under 21 with a complex medicaid diagnosis and those under institutionalized care have been pushed to the very end of the redetermination period, ensuring plenty of time for communication and outreach with limited lapse in coverage. 

‍

The state has emphasized a “common-sense” approach to redetermination, but it’s worth noting Florida has become a prime illustration of the difficulties that can come with unwinding without the use of appropriate assistive technologies and software. For example, Florida does not use available government databases to determine eligibility, can take weeks to process Medicaid applications and has documented difficulty reaching Medicaid patients. It may become a textbook case for the importance of having the right technologies in place prior to a disruptive event like redetermination. 

• California 

The first state to release its approach publicly, California is also taking a flexible, state-determined approach to unwinding. There are two main phases to its approach. 

‍

First, California has emphasized it will be using the full, allotted 12-month period for redetermination, buying all patients and providers as much time as possible to prepare. Second, the state has adopted somewhat of a time-based approach in that it will maintain each patient’s pre-PHE renewal month. If a patient was eligible for renewal in June 2020, their renewal date will now be June 2023. California’s plan emphasizes the importance of order and organization in its renewal timeline. 

‍

From there, California’s approach includes a series of small, but impactful policies designed to reduce churn and maintain coverage for eligible populations. As the largest Medicaid program in the country, it makes sense that California would implement its own rules regarding ex parte renewals, coverage for minors, presumptive eligibility, premium waivers, available databases and more. A full explanation of California unwinding guidelines can be found here. 

‍

But that’s not all - California will also provide its own PHE dashboard to monitor trends in enrollment and eligibility, available on the Department of California Health Services (DCHS) website. The DCHS has also released specific resources and timeline guidance for each 60-day renewal period. More information on this timeline can be found here. 

Moving forward with Medicaid redetermination

To best serve your patient population and prevent lapses in coverage, you must know your state’s plan for unwinding. Even if you aren’t quite sure of your role in the unwinding process just yet, this is your starting point. 

Know what your patient population will be required to do to renew and what data is available for you to use. Then, take this data and research and decide how you can best coordinate with federal and state officials to navigate Medicaid redetermination. 

If this process already feels overwhelming to you, you’re not alone. Luckily, the tools and technology required to navigate this process are already available and standing by for you to use. 

Office Ally has been operating in the insurance verification and Medicaid eligibility and enrollment space for more than 20 years. We’re proud to serve as a trustworthy source of information and customizable software solutions to help you come out of this transition on top. 

‍We’re here to help. Contact Office Ally today to connect with one of our experts for more information.