Some states are falling short in their efforts to process Medicaid renewal applications and are inappropriately finding too many people ineligible to continue participating in the program, the Centers of Medicare & Medicaid Services has written in a letter it sent to all 50 states.

In this letter, CMS wrote that

As the Centers for Medicare & Medicaid Services (CMS) has worked with states on the return to regular eligibility operations following the end of the Medicaid continuous enrollment condition, we have identified issues where states are out of compliance with renewal requirements. CMS has worked with those states individually to remediate the issues identified, including by requesting that states pause procedural terminations, reinstate coverage for individuals whose coverage was inappropriately terminated and implement mitigation strategies to prevent future inappropriate disenrollments.

The letter goes on to explain that CMS

… has learned of additional systems and operational issues affecting multiple states, which may be resulting in eligible individuals being improperly disenrolled. Specifically, we understand that some states are conducting ex parte renewals at the household level, without regard to differing eligibility statuses and income thresholds for individuals within the household. As a result, while a state may have sufficient information during the ex parte process to renew Medicaid or CHIP coverage for some individuals in a multi-member household, states are sending renewal forms requesting information for all household members, and, if the renewal form is not returned, states are disenrolling all individuals in the household, including those who should have been determined to be eligible through the ex parte process. As discussed in more detail below, these actions violate federal renewal requirements and must be addressed immediately.

CMS reports that this problem with ex parte renewals – auto-renewals – most frequently arises for children in households with at least one adult enrolled in Medicaid and eligible individuals in a household in which additional documentation is needed to verify eligibility for the other household members.

If CMS informs a state that it has a problem with this process, the state must immediately take the following steps to avoid CMS taking action to bring it into compliance:

  • pause procedural disenrollments for those individuals affected
  • reinstate coverage for all affected individuals
  • implement one or more CMS-approved mitigation strategies to prevent continued inappropriate disenrollments
  • fix systems and processes to ensure that renewals are conducted appropriately and in accordance with federal Medicaid requirements

This is not the first time CMS has attempted to call states to account for the shortcomings in their Medicaid renewal efforts.  Only two weeks ago the agency sent individual letters to every state  specifying the nature of their failures.

Learn more about CMS’s action from this agency news release; the letter it sent to the states; and the Healthcare Dive article “Medicaid cracks down on states over children wrongly losing coverage during redeterminations.”  In addition, CMS has offered states a mitigation template for addressing ex parte renewal compliance issues.  Find that template here.