Medicaid Unwinding

Back on November 5th, just a few days into the 2024 Open Enrollment Period, I did some back-of-the-math number crunching and concluded that the odds were pretty good that total 2024 OEP ACA enrollment (including both exchange-based Qualified Health Plans, or QHPs, as well as enrollment in Basic Health Plans (BHPs) in New York & Minnesota only) would break 19 million people for the first time in the ACA's history.

This was based on some simple assumptions:

Normally, states will review (or "redetermine") whether people enrolled in Medicaid or the CHIP program are still eligible to be covered by it on a monthly (or in some cases, quarterly, I believe) basis.

However, the federal Families First Coronavirus Response Act (FFCRA), passed by Congress at the start of the COVID-19 pandemic in March 2020, included a provision requiring state Medicaid programs to keep people enrolled through the end of the Public Health Emergency (PHE). In return, states received higher federal funding to the tune of billions of dollars.

As a result, there are tens of millions of Medicaid/CHIP enrollees who didn't have their eligibility status redetermined for as long as three years.

Originally posted 10/31/23; updated 11/08/23

Back in September, Amy Lotven of Inside Health Policy found an excellent scoop from a new CMS report hiding in plain sight:

New CMS data, quietly released in late August, show about 178,000 consumers chose a qualified health plan (QHP) through a state or federal exchanges after losing Medicaid and CHIP coverage in the first two months of the Medicaid unwinding. Those sign-ups through the end of May are more than three times the 54,000 enrollments that CMS reported in July, which reflected only the April numbers.

Last week I reported that at least 593,000 of the "Medicaid Unwinding" population (Americans who had their Medicaid or CHIP coverage terminated since the end of the COVID public health emergency's "Continuous Coverage" provision ended at the end of March) had shifted over to an ACA exchange plan as of the end of July (plus another 88K who enrolled in BHP plans).

As I noted at the time, perhaps 11% or so of the Unwinding population might move to ACA exchange policies instead when the dust settles on the ongoing unwinding process (12% or so if you include BHP enrollees).

Today, Amy Lotven of Inside Health Policy reports some additional data which indirectly supports this:

As long-time readers know, every year during the ACA Open Enrollment Period (OEP) I have a tradition of regularly updating a graph tracking how many Americans have enrolled in on-exchange Qualified Health Plan (QHP) policies nationally. The Graph®, as I've come to call it, is how this entire website got started; the logo for ACA Signups even consists of a stylized version of the original version from the 2013 - 2014 OEP.

That first year I attempted to track every conceivable population--on-exchange QHPs, off-exchange QHPs, Medicaid expansion enrollment, SHOP (ACA small business exchange) enrollees) and even the amorphous "sub-26er" populations of young adults enrolled in their parents employer plans thanks to ACA provisions. Some of these were nearly impossible to accurately estimate, but I really tried my best.

Over the next year or two, I not only dropped the categories which I wasn't able to track properly, my tracking of the remaining ones became much more streamlined and sophisticated. Eventually I decided to stick with just two categories: On-exchange QHPs and those enrolled in the Basic Health Plan (BHP) programs in Minnesota and New York.

SEE IMPORTANT UPDATES AT BOTTOM.

Yesterday I crunched the numbers for two different reports from the Centers for Medicare & Medicaid services.

The first was the standard monthly Medicaid/CHIP enrollment report for June 2023:

In June 2023, 92,614,205 individuals were enrolled in Medicaid and CHIP.

  • 85,614,581 individuals were enrolled in Medicaid in June 2023, a decrease of 1,169,095 individuals (1.3%) from May 2023.
  • 6,999,624 individuals were enrolled in CHIP in June 2023, a decrease of 32,449 individuals (0.5%) from May 2023.

As of June 2023, enrollment in Medicaid and CHIP has decreased by 1,304,004 since March 2023, the final month of the Medicaid continuous enrollment condition under the Families First Coronavirus Response Act (FFCRA) and amended by the Consolidated Appropriations Act, 2023.

Washington HealthPlan Finder

via the Washington HealthPlan Finder:

Today, the Washington Health Benefit Exchange (Exchange) released a Data Snapshot Report, which shows the availability of affordable, Cascade Care plans are proving critical to keeping people covered and advancing equity during the Medicaid unwind.

Now that COVID-era protections have expired, Washington, like all states, has resumed regular annual eligibility checks for people covered by our state Medicaid program, Washington Apple Health. For the past year, the Exchange has joined partners across our state, led by the Washington Health Care Authority (HCA), to ensure Apple Health customers watch out for and respond to renewal notices.

Last month, Amy Lotven of Inside Health Policy found an excellent scoop from a new CMS report hiding in plain sight:

New CMS data, quietly released in late August, show about 178,000 consumers chose a qualified health plan (QHP) through a state or federal exchanges after losing Medicaid and CHIP coverage in the first two months of the Medicaid unwinding. Those sign-ups through the end of May are more than three times the 54,000 enrollments that CMS reported in July, which reflected only the April numbers.

Three weeks ago, the Centers for Medicare & Medicaid Services (CMS) announced that they were cracking down on one of the main reasons why so many people are being kicked off of Medicaid and the Children's Health Insurance Program (CHIP) even though they were still eligible: 

CMS believes that eligibility systems in a number of states are programmed incorrectly and are conducting automatic renewals at the family-level and not the individual-level, even though individuals in a family may have different eligibility requirements to qualify for Medicaid and CHIP. For example, children often have higher eligibility thresholds than their parents, making them more likely to be eligible for Medicaid or CHIP coverage even if their parents no longer qualify. This conflicts with existing federal Medicaid requirements and may have a disproportionate impact on children.

Yesterday I noted that Idaho, which was the one of the first states to start "redetermining" Medicaid/CHIP enrollees the moment the Medicaid Unwinding process began last spring, has at least completed doing so; in the end, over 121,000 - 145,000 Idahoans got the boot, of which somewhere between 51,000 - 106,000 may still actually be eligible for Medicaid/CHIP coverage due to having their coverage terminated for purely procedural reasons.

Today, there's a consolation prize of sorts; via Your Health idaho:

Special Enrollment Period for the Loss of Medicaid Extended

Idahoans who have lost Medicaid coverage have until Nov 30, 2023, to enroll in health insurance through Your Health Idaho

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