Medicaid Redetermination Update: What Changed in 2024?

In 2024, we finally saw the conclusion of the Medicaid Redetermination process. Redetermination, or unwinding, as the Centers for Medicare and Medicaid Services (CMS) has called it, first began in 2022. Since then, the healthcare industry has been anxiously watching as the end of pandemic-era protections started to impact millions of enrollees. 

We’ve come a long way from the last time we talked about the redetermination process this past April. As things wrap up, we’re revisiting the early outcomes of redetermination to provide updated insights and recommendations.

What Happened in 2024?

By January 2024, every state was well into the redetermination process, and two trends became clear. 

One: ex parte renewals were positively contributing to re-enrollment. These renewals are granted based solely on available data and do not require active reapplication from the enrollee. It allows states to re-enroll people faster and avoid excess Medicaid churn or gaps in coverage.

And two, unfortunately, in cases where enrollees did have to submit applications, states often fell short in effectively processing them. Many states took longer than the allotted 45-day period to process applications, meaning many patients had to sit uninsured for more than a month.

As the number of people disenrolled surpassed 20 million in early 2024 (eventually coming to rest on around 25 million total disenrolled people), CMS began to address backlogs to speed up application processing. They released guidelines designed to re-enroll people as quickly as possible as redetermination came to an end for nearly all states by late September. 

Post-Redetermination Updates

The unwinding of pandemic-era protections has resulted in significant changes to Medicaid enrollment. In April 2023, a record 94 million people were enrolled in Medicaid. Today, that number is down to 79.4 million people.

According to a KFF report, tens of millions of individuals have faced renewal processes, often for the first time in years. Key findings include:

• High Disenrollment Rates: Approximately 74% of disenrollments were procedural, meaning individuals lost coverage due to incomplete or incorrect paperwork, not because they were ineligible.  
• Coverage Gaps: Medicaid churn became a significant problem as half of all people disenrolled were still eligible, but had to wait for bureaucratic holdups to re-obtain coverage.
• State Variability: Renewal outcomes vary widely by state, with some achieving higher success rates in re-enrolling eligible individuals than others.  

Throughout the entire redetermination process, low-income families, children, and individuals in marginalized communities remained most at risk. Many struggled with the administrative hurdles of re-enrollment or are unaware they need to take action. CBPP’s “Unwinding Watch” often highlighted the disproportionate impact of these issues on communities with limited access to digital or in-person assistance for Medicaid applications.

Now CMS is handling the aftermath and learning from these findings to prevent future instances of high churn and procedural disenrollment. 

Recent Changes to CMS Guidelines

In November 2024, CMS issued four new bulletins explaining updated guidelines to improve processes in the wake of redetermination.

1. Income estimates

Previously, many income estimate practices required a special waiver from CMS. As of November 14, the following practices are allowed without a waiver:

• Using income estimates from the Supplemental Nutrition Assistance Program (SNAP) for the MAGI population.
• Streamlining the asset verification system (AVS)/asset determinations
• Letting Managed Care Organizations (MCOs) help with form completion
• Fast-tracking renewals for people with stable income and assets
• Allowing an ex-parte renewal when income information cannot be found through available data sources.

Removing the need for a waiver helps increase ex parte renewals and, consequently, retention. The logistics are complex, so we recommend reading the full bulletin for clarification.

2. Compliance requirements

Unfortunately, not every state handled redetermination with the same level of success. In 2023, some states actually had to pause renewals as CMS found many people were disenrolled due to errors on a state level. Other states struggled to keep up with the flood of renewal applications. 

To combat this, CMS introduced new proof of compliance requirements on November 15. States must now show proof of:

• Required attempts at ex parte renewals
• Options for renewal online and over the phone
• Sending pre-populated renewal forms

All states must complete a compliance template by December 31, 2024. Along with this, they must submit materials showing workflows, documented processes, sample renewal packets, and other requirements. Everything is designed to give CMS a better understanding of what states are seeing more success and why so they can implement best practices on a wider scale. 

If states are found to have areas of noncompliance, they are required to develop a documented improvement plan with check-ins to CMS every six months and guaranteed compliance by December 31, 2026. 

3. Handling Attested Income

When a person’s income cannot be verified because different sources report different amounts, it often holds up the renewal process. To fix this, CMS released a bulletin in late November with strategies for handling attested income. 

The bulletin provided mandatory and optional data sources for verifying income, outlined reasonable compatibility thresholds for income and assets, and identified strategies to reconcile information based on source hierarchy. These are small tweaks, but the guidance will hopefully make a big difference in speeding up income verification. 

4. Improving Ex Parte Renewals

Ex parte renewals have been identified as a key element of reducing Medicaid churn throughout unwinding. In recognition of this, CMS released a second bulletin in late November with guidelines for increasing ex parte renewals. 

The guidance includes data hierarchy information and renewal notice requirements and reiterates the requirement for attempting an ex parte renewal for all applicants.

What’s Next? Steps for Healthcare Stakeholders

CMS isn’t the only organization that needs to think about making big changes as Medicaid redetermination ends. The redetermination process has created challenges for providers and payers alike, including:

• Increased Administrative Burden: Providers must dedicate resources to verify coverage and assist patients in navigating renewals.  
• Revenue Risks: Higher rates of uninsured patients can lead to increased uncompensated care costs.  
• Care Continuity Concerns: Providers must address gaps in care that can result from coverage interruptions.

No one expected a global pandemic to come around, but COVID-19 was an indication we can never predict the future. Providers need to have tools in place now to avoid complications in the future. Screening, enrollment and application tools must securely handle data. Patient communication tools must provide secure, user-friendly ways to communicate with patients to streamline future application processes. And, perhaps above all, providers must continue to advocate for patients, helping them maintain Medicaid enrollment via education and financial counseling programs. 

Office Ally remains committed to helping healthcare providers and payers rise to meet these challenges. We’re prepared to help “future-proof” your organization with comprehensive solutions designed to streamline workflows, reduce administrative burden and improve patient outcomes.

Get started: Learn more about MAPS, Office Ally’s all-in-one screening and enrollment platform designed to find and maintain coverage for self-pay patients.

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