States Leverage Waivers To Support Medicaid Redetermination

States flocked toward ex parte renewals and contact information update waivers to support Medicaid redetermination processes after the coronavirus public health emergency ended, a KFF brief found.

For six months, Medicaid has been in a state of “unwinding” as the program restarted typical processes following the end of continuous enrollment. As experts predicted, the efforts to return to normal have hit many roadblocks, with CMS identifying system errors that wrongfully disenrolled eligible beneficiaries and pausing the disenrollment process as a result in September 2023.

To cope with the high volume of redeterminations, states turned to Medicaid waivers. There are four main types of waivers that apply to this process: waivers that increase ex parte renewals, support enrollees’ form submissions, perform enrollee contact updates, and re-enroll beneficiaries whose coverage was terminated due to a procedural error.

After reviewing states’ waivers, KFF identified a couple of pervasive trends characterizing states’ efforts to keep eligible beneficiaries enrolled in Medicaid.

Almost every state adopted a waiver to increase ex parte renewals—a process that allows beneficiaries to re-enroll without submitting any paperwork. As of January 16, 2024, 49 states had adopted at least one waiver related to ex parte renewals, resulting in 200 ex parte renewal waivers.

Most states (38) allowed ex parte renewals for no- or low-income individuals. Additionally, 33 states adopted processes that presume that no new information submitted means the beneficiary did not experience a change in assets, in which case states do not have to verify the beneficiary’s information or they can verify it through a simplified process.

A strong contingent of states (27) allowed Supplemental Nutrition Assistance Program (SNAP) or Temporary Assistance for Needy Families (TANF) eligibility to function as verification for Medicaid eligibility.

Another common approach that states adopted was to use waivers that supported enrollees’ contact information updates. While states have a variety of sources at their disposal for confirming enrollees’ personal information, such as the address where the state should send their Medicaid coverage renewal forms, many states adopted waivers that expanded the number of resources they could reference for verification.

More than half of the states adopted waivers that supported renewal form submission processes. Most of these waivers enable Medicaid managed care organizations (MCO) to offer more support in completing the form than normal, extending even to sections that are not related to the MCO. Other waivers allow beneficiaries to identify an authorized representative by phone.

Only 19 states adopted waivers to support individuals who were disenrolled due to procedural causes. These types of waivers help wrongfully disenrolled beneficiaries regain coverage. Some states extended the automatic re-enrollment timeframe while others extended the amount of time for fair hearing requests.

“Efforts to improve renewal processes and reduce procedural disenrollments will likely last beyond the unwinding period, and CMS and states may look to extend some unwinding flexibilities and/or make some permanent for regular operations,” the brief concluded.