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CMS Uncovers Problems With State Medicaid Redeterminations
A few months ago, I prepared a commentary on the state Medicaid redetermination process mandated by the Consolidated Appropriations Act of 2022. The present comments supply an important update.
The Consolidated Appropriations Act of 2022 ended the Medicaid continuous enrollment requirement on March 31, 2023, and started a phase down of federal Medicaid matching funds by December 2023. Continuous Medicaid enrollment originally was mandated under the Families First Coronavirus Response Act at the beginning of the COVID-19 pandemic.
The continuous enrollment mandate resulted in an expansion of the Medicaid population from about 72 million to 95 million enrollees nationally between 2020 and 2023. Kaiser Family Foundation has estimated that between 8 million and 24 million persons could be disenrolled from Medicaid as part of the redetermination process. Assuming conservatively that overall prevalence rates for behavioral conditions (25% annual prevalence for children and adults) apply to this group, that would mean between 2 million and 6 million children and adults with behavioral health conditions ultimately could be disenrolled.
It is well known that people with behavioral health conditions can have great difficulty enrolling in health insurance and remaining enrolled. That is why the current mandated Medicaid enrollment redeterminations are so concerning to the field.
What actually has occurred in the Medicaid redetermination process since it began in the spring of this year?
Kaiser Family Foundation reports that more than 7 million Medicaid beneficiaries have been disenrolled from the program since the redetermination process began. Kaiser also notes exceptionally wide variation in disenrollment rates across reporting states, ranging from 69% in Texas to 14% in Maine and Oregon. Overall, and estimated conservatively, we would expect that about 1.75 million of these disenrollments have been for persons with behavioral health conditions.
Further, just a few days ago, the Centers for Medicare and Medicaid Services (CMS) ordered 30 states to pause procedural disenrollments of Medicaid beneficiaries. This administrative process was inappropriately removing children and other enrollees from coverage. Some states were conducting eligibility checks at the family level, even though particular members of the household—like children—face a lower bar to remain covered under the safety program. States will be required to correct this problem before procedural disenrollments can resume.
According to preliminary CMS data, the following states were not auto-renewing at the individual level: Alaska, Colorado, Connecticut, Delaware, Washington, D.C., Georgia, Hawaii, Idaho, Illinois, Iowa, Kansas, Kentucky, Maine, Maryland, Massachusetts, Minnesota, Nebraska, Nevada, New Jersey, New Mexico, New York, North Dakota, Ohio, Oregon, Pennsylvania, Vermont, Virginia, West Virginia, Wisconsin, and Wyoming.
Nearly 500,000 children and other individuals who were improperly disenrolled from Medicaid or CHIP will regain their coverage according to CMS, and many more are expected to be protected from improper disenrollments going forward.
The lessons for us seem quite clear. First, we must play a highly active role in this process and actually understand how our respective states are conducting these Medicaid redeterminations. Second, when individuals and families with behavioral health conditions are disenrolled, we need to investigate whether the disenrollments were appropriate or inappropriate. Third, we also need to help individuals and families re-enroll when they still are eligible, because this may not occur automatically within a state’s redetermination process.
Ron Manderscheid, PhD, is the former president and CEO of NACBHDD and NARMH, as well as an adjunct professor at the Johns Hopkins Bloomberg School of Public Health and the USC School of Social Work.
The views expressed in Perspectives are solely those of the author and do not necessarily reflect the views of Behavioral Healthcare Executive, the Psychiatry & Behavioral Health Learning Network, or other Network authors. Perspectives entries are not medical advice.
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