AARP MARCH 2023 PUBLIC POLICY INSTITUTE Fact Sheet Resumption of Medicaid Eligibility Reassessments: Over 1 Million Enrollees Ages 50 to 64 Could Lose Their Benefits Tobey Oliver AARP Public Policy Institute Before the COVID-19 pandemic, state Medicaid programs typically reassessed enrollees' eligibility at least once a year and would disenroll them if they no longer qualified. The pandemic put that practice on hold, however, with a federal law passed in March 2020 that required state Medicaid programs to keep people enrolled throughout the public health emergency. States received enhanced federal funding for implementing the requirement.! This policy-often referred to as continuous enrollment-has led to a record-high Medicaid enrollment of more than 84 million people as of November 2022." Rates of uninsured Americans have also dropped to record levels, hitting a low of 8 percent in early 2022.3 Overall, continuous enrollment helped ensure that tens of millions of people did not have to worry about losing health coverage during a time of health and economic uncertainty. However, major changes are coming soon. A spending bill that passed at the end of 2022 is ending the continuous coverage protection, and state Medicaid programs will once again be able to disenroll people who are no longer eligible starting on April 1, 2023.4 Previous analyses suggest that 5 to 17.5 percent of Medicaid enrollees could lose coverage during this "unwinding" process.* The AARP Public Policy Institute (PPI) contracted with NORC at the University of Chicago to further examine the implications of the unwinding process for older Americans. NORC analyzed Medicaid enrollment trends for the 50-to-64 population before and during the public health emergency and used these data to model the impact of resuming Medicaid eligibility reassessments, or redeterminations, in this population. This paper discusses these findings as well as their context within the larger health care system. We also provide an overview of federal and state actions taken in advance of the April 1 changeover date and discuss policy options that could help ease the transition. Impact on the 50-to-64 population NORC's model predicts that the unwinding process could result in 1 million people ages 50 to 64 being dropped from Medicaid over the next year, from approximately 12.2 million as of March 31, 2023, to an estimated 11.2 million on April 1, 2024. This finding is due to a few factors. Some individuals will be disenrolled because they no longer qualify ¢.g., if their income has increased), whereas others who might otherwise still qualify will be disenrolled due to administrative reasons-not receiving necessary information, not understanding material explaining steps they need to take and therefore failing to take those steps, and otherwise falling through the cracks. MARCH 2023 Notably, NORC's model is based on disenrollment trends prior to the public health emergency. Because this historical data is not reflective of the unique challenges created by the public health emergency or sudden resumption of eligibility reassessments, our findings could in fact underestimate enrollment changes. Examples of factors associated with this uncharted territory include the following: e Record-high Medicaid enrollment requires a record-high number of redeterminations.® States will have a limited time until June 1, 2024 to complete all eligibility redeterminations and disenrollments, and state Medicaid officials report that agencies are understaffed and have lost institutional knowledge on conducting the redetermination process.' e Newer Medicaid enrollees are likely not as familiar with the redetermination process and how to complete it because many have not gone through it previously. e Enrollees may have moved and not updated their address with their state Medicaid agency and therefore may not receive their redetermination notice. A Kaiser Family Foundation analysis found that about 10 percent of Medicaid enrollees moved in 2020 alone.® Despite the anticipated drop in enrollment due to the unwinding process, NORC's model estimates that the overall number of Medicaid enrollees ages 50 to 64 will be 24 percent larger in June 2024 than it was just before the start of the pandemic (i.e., February 2020). The number of people ages 50 to 64 who are enrolled in Medicaid is expected to increase by just over 1 million between February 2020 and June 2024. Predictions for growth rates and disenrollment rates vary significantly by state, as detailed in the appendix. Other coverage options, and connecting consumers to them In considering the end of continuous coverage protections for Medicaid beneficiaries, it is worthwhile to consider other health care coverage options that individuals may be able to access. Some people who no longer qualify for Medicaid may have access to health insurance coverage through their job or employer. Also, people who lose Medicaid eligibility due to higher income may be eligible for financial assistance to defray the cost of a private health insurance plan on the Health Insurance Marketplace (Marketplace), created by the Affordable Care Act. An analysis by the Office of the Assistant Secretary for Planning and Evaluation found that almost one-third of individuals who lose Medicaid coverage will qualify for Marketplace premium assistance. Most of these individuals (60 percent) may be eligible to have their premiums fully covered.° However, research has shown that among those individuals who lose Medicaid coverage but are eligible to move to subsidized Marketplace plans, few actually enroll. A recent study by the Medicaid and Children's Health Insurance Program (CHIP) Payment and Access Commission (MACPAC) found that only about 3 percent of people who disenrolled from Medicaid enrolled in a Marketplace plan within a year.!° The federal government has put in place several policies to help ease the transition from Medicaid to Marketplace coverage, including financial assistance, enrollment windows, and connections between the Medicaid and Marketplace eligibility processes. Federal financial assistance in the form of premium tax credits and cost-sharing reduction subsidies are available to help people afford Marketplace coverage. The availability of premium tax credits, which the federal government has significantly expanded through 2025, make these plans more affordable to individuals transitioning from Medicaid." Recent PPI analyses estimate that these tax credit expansions are critical to making health coverage affordable and can save older adults up to $4,700 in premiums and ensure that 1 million fewer older adults ages 50 to 64 are uninsured." MARCH 2023 In addition to providing this financial assistance, to help people enroll in Marketplace coverage, the federal government created a temporary "unwinding" special enrollment period (SEP) for people losing Medicaid or CHIP coverage between March 31, 2023 and July 31, 2024." People may also be eligible for other SEPs,"* and people in most states with income levels under 150 percent of the federal poverty level and who are also eligible for premium tax credits may be eligible to enroll year-round. Meanwhile, in anticipation of the unwinding, state Medicaid officials have been working closely with their Marketplace counterparts, and both states and the federal government have been developing communication strategies to help ensure that people who lose Medicaid are aware of Marketplace coverage options and the availability of financial assistance. Ifa state determines an individual's income to be too high for Medicaid, it sends the applicant's information to the Marketplace, helping connect the two programs for the user. The Marketplace eligibility system then sends a letter to the person with information and instructions on enrolling in a Marketplace plan. Other federal and state efforts to mitigate impact of unwinding process Federal- and state-level agencies have been actively working to prepare for the unwinding in other areas as well. The Centers for Medicare and Medicaid Services (CMS) has been encouraging enrollees to update their contact information with Medicaid agencies and to be on the lookout for communications about redeterminations. Federal and state officials have also been working to improve coordination between Medicaid and Marketplace enrollment processes and make improvements to the redetermination process to cut down on disenrollments due to administrative reasons. An enrollee's redetermination experience will in part depend on their state. For example, many states use available data to reduce the amount of information enrollees need to submit, and some states have focused on improving data use and implementing other system upgrades in the past few years. However, the extent of data use and burden on enrollees vary widely.'* States have also employed varying approaches to education and outreach and making information public." (For specific examples of steps some states are taking, see box "Notes From a MACPAC Meeting: What States Are Doing on the Ground.") Amid these varying efforts and even despite the more proactive ones, many people may remain unaware of the upcoming changes. As of December 2022, more than 64 percent of adults who are enrolled in Medicaid, or who have a family member who is enrolled, were unaware of the upcoming redetermination process. Additional efforts needed People who lose health insurance coverage completely, even for short periods (sometimes referred to as "churn"), are likely to experience both financial and medical adverse impacts. Loss of health care coverage leads people to skip needed care and incur high costs to pay for the care they do get.!® These stakes are also higher for those ages 50 to 64 than for younger groups: e Twenty percent of 50- to 64-year-olds report being in fair to poor health, compared with 11 percent of those ages 18 to 49. For those who make less than 25,000 a year, this number rises to 48 percent."° e People ages 54 to 64 also report higher rates of multiple common chronic health conditions compared with younger cohorts."! Given the implications for millions of people, as well as the increased reliance on Medicaid among the 50-to-64 population, policymakers should ensure that the unwinding/Medicaid redetermination process goes as smoothly as possible. Priorities should include the following: Ensuring sufficient state staffing. For a redetermination effort to be successful, states will need to ensure adequate staff in MARCH 2023 Process to other safety net services provide Engaging enrollees enrollees Notes From a MACPAC Meeting: What States Are Doing on the Ground During a January 2022 public meeting of the Medicaid and CHIP Payment and Access Commission, several state representatives discussed planning and process updates that they hope will help the redetermination process go more efficiently and effectively." Highlights of such updates taking place included improvements to the reassessment process and ways to engage enrollees more effectively: e« Improved performance management and monitoring tools, including new dashboards e Additional external support in coordinating enrollment between Medicaid and Marketplace plans and referrals e Better use of data to streamline the process and minimize the amount of information that enrollees must e Media campaigns to alert enrollees to the upcoming process e Updating and improving enrollee communication materials and sharing sample language and clear messaging strategies with community partners for consistent messaging to enrollees e Creation of a return-mail center to standardize processes for undeliverable mail and take further steps to reach several pivotal roles, including eligibility case workers, call center staff, eligibility systems support, and determination appeals staff. This is an area of risk for states because many current staff members have expressed concern about adequate staffing. CMS has gathered some best practices for states to address these challenges, such as cross- training state and county staff from other agencies to help fill roles on a temporary basis and creating specialized units to handle more complex tasks." Opportunities for enrollee feedback. So that officials can address systemic issues as quickly as possible, states should ensure they have robust channels in place to gather reports of enrollee concerns and problems experienced in the redetermination process. Addressing issues quickly will help ensure that enrollees stay covered or transition smoothly to other available coverage options. Education and outreach efforts. CMS and states should stay engaged with communities to provide resources, such as those that help explain the redetermination process or direct people to local legal or advocacy entities that can help them navigate the process. Improved monitoring. States must submit reports to CMS on the redetermination and disenrollment processes, and CMS must make the reports publicly available." CMS has not yet provided information on how or where it will publish these reports but will likely provide updates on its website dedicated to guidance and information on this process.** These reports can provide important information for policymakers and reveal insights that warrant further investigation. MARCH 2023 Appendix Tice ati alate liy <3 Pace) rier lit < 50- to 64-year 50- to 64-year 50- to 64-year UEC aa li elu aa a is oldenrollment old enrollment oldenrollment pandemic (February (February 2020) to 2/1/20 4/1/23 rR UPL 2020) to 4/1/23 4/1/24 State [observed] [projected] yay (raced [projected] [projected] AK 28,233 34,936 32,492 23.7% 15.1% AL 89,940 106,915 106,440 18.9% 18.3% AR 113,650 148,644 134,946 30.8% 18.7% AZ 221,059 317,039 286,770 43.4% 29.7% CA 1,600,331 2,068,897 1,783,519 29.3% 11.4% co 167,181 253,356 222,479 51.5% 33.1% CT 127,597 159,324 150,234 24.9% 17.7% DC 40,495 48,133 46,680 18.9% 15.3% DE 33,643 45,031 39,302 33.9% 16.8% FL 289,744 411,185 414,120 41.9% 42.9% GA 145,638 178,673 175,908 22.7% 20.8% HI 45,667 70,529 60,565 54.4% 32.6% IA 86,552 110,578 105,155 27.8% 21.5% ID 35,618 56,261 49,940 58.0% 40.2% IL 377,313 575,520 525,682 52.5% 39.3% IN 200,617 309,433 298,495 54.2% 48.8% KS 34,603 40,169 40,246 16.1% 16.3% KY 195,730 251,609 224,542 28.5% 14.7% LA 198,285 267,793 247,840 35.1% 25.0% MA 255,890 351,230 346,109 37.3% 35.3% MD 170,787 230,496 205,108 35.0% 20.1% ME 42,238 66,555 68,121 57.6% 61.3% Ml 335,405 449,437 376,027 34.0% 12.1% MN 127,040 174,225 164,100 37.1% 29.2% MO 99,412 172,342 161,962 73.4% 62.9% MS 74,650 84,886 86,248 13.7% 15.5% MT 35,515 47,151 48,406 32.8% 36.3% NC 181,312 248,121 240,327 36.8% 32.5% ND 10,679 14,876 13,265 39.3% 24.2% NE 18,130 33,813 30,744 86.5% 69.6% NH 23,715 36,710 32,216 54.8% 35.8% NJ 239,905 322,211 301,808 34.3% 25.8% NM 95,788 122,210 113,288 27.6% 18.3% NV 84,400 126,588 123,176 50.0% 45.9% MARCH 2023 Enrollment change Enrollment change 50- to 64-year 50- to 64-year 50- to 64-year from start of from start of pandemic old enrollment | old enrollment old enrollment | pandemic (February (February 2020) to 2/1/20 4/1/23 4/1/24 2020) to 4/1/23 rR UPL [observed] [projected] [projected] [projected] [projected] NY 942,988 1,260,072 1,180,737 33.6% 25.2% OH 368,107 480,415 445,755 30.5% 21.1% OK 69,823 104,841 95,114 50.2% 36.2% OR 157,096 233,041 189,287 48.3% 20.5% PA 440,763 583,754 506,244 32.4% 14.9% RI 50,534 68,932 67,081 36.4% 32.7% SC 99,960 124,788 120,923 24.8% 21.0% SD 8,313 10,243 10,085 23.2% 21.3% TN 148,804 173,753 167,076 16.8% 12.3% TX 254,215 312,116 302,061 2.8% 18.8% UT 28,817 48,854 45,261 69.5% 57.1% VA 191,858 291,198 300,732 51.8% 56.7% VT 23,174 32,178 29,805 38.9% 28.6% WA 225,712 306,796 276,211 35.9% 22.4% WI 131,680 186,196 167,933 41.4% 27.5% WV 86,331 107,038 94,269 24.0% 9.2% WY 4,656 6,466 6,619 38.9% 42.2% Endnotes 1 2 Families First Coronavirus Response Act, Pub. Law No, 116-127, 2020, https://www.govinfo.gov/app/details/PLAW-116publ127, "November 2022 Medicaid & CHIP Enrollment Data Highlights," Centers for Medicare & Medicaid Services (CMS), accessed February 6, 2023, https://www.medicaid.gov/medicaid/program-information/medicaid-and-chip-enrollment-data/report-highlights/index.html. Aiden Lee, Joel Ruhter, Christie Peters, Nancy De Lew, and Benjamin D. Sommers, "National Uninsured Rate Reaches All-Time Low in Early 2022," Office of the Assistant Secretary for Planning and Evaluation (ASPE), Data Point, August 2022, https://aspe.hhs.gov/ reports/2022-uninsurance-at-all-time-low. Consolidated Appropriations Act, 2023, SEC. 5131, "Transitioning From Medicaid FMAP Increase Requirements," (tt)(1) https:// www.congress.gov/117/bills/hr2617/BILLS-117hr2617enr.pdf. Jennifer Tolbert and Meghana Ammula, "10 Things to Know About the Unwinding of the Medicaid Continuous Enrollment Provision," Kaiser Family Foundation (KFF), January 11, 2023, https://www.kff.org/medicaid/issue-brief/10-things-to-know- about-the-unwinding-of-the-medicaid-continuous-enrollment-provision/; Matthew Buettgens and Andrew Green, "The Impact of the COVID-19 Public Health Emergency Expiration on All Types of Health Coverage," Urban Institute, Research Report, December 2022, https://www.urban.org/sites/default/files/2022-12/The%20I|mpact%200f%20the%20COVID-19%20Public%20Health%20 Emergency%20Expiration%200n%20All%20Types%200f%20Health%20Coverage_0.pdf; "Unwinding the Medicaid Continuous Enrollment Provision: Projected Enrollment Effects and Policy Approaches," ASPE, Office of Health Policy, /ssue Brief, August 19, 2022, https://aspe.hhs.gov/reports/unwinding-medicaid-continuous-enrollment-provision. "Transitions Between Medicaid, CHIP, and Exchange Coverage," Medicaid and CHIP Payment and Access Commission (MACPAC), Issue Brief, July 2022, https://www.macpac.gov/wp-content/uploads/2022/07/Coverage-transitions-issue-brief.pdf. "Public Meeting," MACPAC, January 20, 2022, pp. 126-29, accessed February 16, 2023, https://www.macpac.gov/wp-content/ uploads/2021/04/MACPAC-January-2022-Meeting-Transcript.pdf. MARCH 2023 8 Bradley Corallo and Jennifer Tolbert, "How Many Medicaid Enrollees Moved in 2020 and What Are the Implications for Unwinding the Public Health Emergency?" KFF, March 17, 2022, https://www.kff.org/medicaid/issue-brief/how-many-medicaid-enrollees- moved-in-2020-and-what-are-the-implications-for-unwinding-the-public-health-emergency/. 9 ASPE, "Unwinding the Medicaid Continuous Enrollment." 10 MACPAC, "Transitions Between Medicaid." 11 The American Rescue Plan Act of 2021 and the Inflation Reduction Act of 2022 together extend expanded tax credits through 2025. See Chiquita Brooks-LaSure and Dr. Ellen Montz, "Inflation Reduction Act Tax Credits Improve Coverage Affordability for Middle-Income Americans," CMS, Blog, August 2022, https://www.cms.gov/blog/inflation-reduction-act-tax-credits-improve- coverage-affordability-middle-income-americans, and Cynthia Cox, Krutika Amin, and Jared Ortaliza, "Five Things to Know about the Renewal of Extra Affordable Care Act Subsidies in the Inflation Reduction Act," August 2022, KFF Policy Watch, https://www. kff.org/policy-watch/five-things-to-know-about-renewal-of-extra-affordable-care-act-subsidies-in-inflation-reduction-act/. 12 Jane E. Sung and Olivia Dean, "Congressional Action Required to Keep Health Coverage Affordable for Many 50- to 64-Year Olds," AARP Public Policy Institute (PPI), AARP Blogs, October 2021, https://blog.aarp.org/thinking-policy/congressional-action- required-to-keep-health-coverage-affordable-for-many-50-to-64-year-olds; see also Jane Sung, Olivia Dean, Robert C. Saunders, Julia Sheriff, and Aig Unuigbe, "Affordability Challenges for Older Adults in the Nongroup Market," AARP PPI, insight on the Issues, March 2021, https://www.aarp.org/content/dam/aarp/ppi/2021/03/affordability-challenges-older-adults-nongroup-market. doi.10.26419-2F ppi.00099.008. pdf. 13 "Temporary Special Enrollment Period (SEP) for Consumers Losing Medicaid or the Children's Health Insurance Program (CHIP) Coverage Due to Unwinding of the Medicaid Continuous Enrollment Condition-Frequently Asked Questions (FAQ)," CMS, Center for Consumer Information and insurance Oversight, January 27, 2023, https://www.cms.gov/technical-assistance-resources/temp- sep-unwinding-faq. pdf. 14 "Special Enrollment Opportunities," HealthCare.gov, accessed March 13, 2023, https://www.healthcare.gov/coverage-outside- open-enrollment/special-enrollment-period/. 15 "An SEP if Your Income Doesn't Exceed 150% of the Federal Poverty Level," Healthinsurance.org, accessed March 13, 2023, https://www.healthinsurance.org/special-enrollment-guide/an-sep-if-your-income-doesnt-exceed-150-of-the-federal-poverty- level/. 16 MaryBeth Musumeci, Molly O'Malley Watts, Meghana Ammula, and Alice Burns, "Medicaid Public Health Emergency Unwinding Policies Affecting Seniors & People with Disabilities: Findings from a 50-State Survey," KFF, Issue Brief, July 2022, https://www.kff. org/report-section/medicaid-public-health-emergency-unwinding-policies-affecting-seniors-people-with-disabilities-findings- from-a-50-state-survey-issue-brief/. 17 "50-State Unwinding Tracker," Georgetown University Health Policy Institute, Center for Children and Families, September 2022, accessed February 17, 2023, https://ccf.georgetown.edu/2022/09/06/state-unwinding-tracker/. 18 Jennifer M. Haley, Genevieve M. Kenney, Stephen Zuckerman, Michael Karpman, Dulce Gonzalez, "Update: Awareness of the Resumption of Medicaid Renewal Processes Remained Low in December 2022," Urban Institute, Fact Sheet, February 16, 2023, https://www.urban.org/research/publication/update-awareness-resumption-medicaid-renewal-processes-remained-low- december. 19 Allyson G. Hall, Jeffrey S. Harman, and Jianyi Zhang, "Lapses in Medicaid Coverage: Impact on Cost and Utilization Among Individuals With Diabetes Enrolled in Medicaid," Medical Care 46, no. 12 (December 2008): 1219-25, https://journals.lww.com/ lww-medicalcare/Abstract/2008/12000/Lapses_in_Medicaid_Coverage__Impact_on_Cost_and.5.aspx; Veri Seo, Travis P. Baggett, Anne N. Thorndike, Peter Hull, John Hsu, Joseph P. Newhouse, and Vicki Fung, "Access to Care Among Medicaid and Uninsured Patients in Community Health Centers After the Affordable Care Act," BMC Health Services Research 19, Article 291, 2019, https://bmchealthservres.biomedcentral.com/articles/10.1186/s12913-019-4124-z; Xu Ji, Adam S. Wilk, Benjamin G. Druss, and Janet R Cummings, "Effect of Medicaid Disenrollment on Health Care Utilization Among Adults with Mental Health Disorders," Medical Care 57, no. 8 (August 2019): 574-83, https://pubmed.ncbi.nlm.nih.gov/31295187/; K. Robin Yabroff, Katherine Reeder-Hayes, Jingxuan Zhao, Michael T Halpern, Ana Maria Lopez, Leon Bernal-Mizrachi, Anderson B Collier, Joan Neuner, Jonathan Phillips, William Blackstock, and Manali Patel, "Health Insurance Coverage Disruptions and Cancer Care and Outcomes: Systematic Review of Published Research," Journal of the National Cancer institute 112, no. 7 (July 2020): 671-87, https://pubmed.ncbi.nlm.nih.gov/32337585/; Joel S. Weissman, Robert Stern, Stephen Fielding, and Arnold M. Epstein, "Delayed Access to Health Care: Risk Factors, Reasons, and Consequences," Annals of Internal Medicine 114, no. 4 (February 1991): 325-31, https://pubmed.ncbi.nlm.nih.gov/1899012/. 20 PPI analysis of 2017-21 Behavioral Risk Factor Surveillance System data. MARCH 2023 21 Prevalence of chronic health conditions for ages 50 to 64 vs. under 50 in 2021: arthritis 35 percent vs. 10 percent; cancer 13 percent vs. 3 percent; chronic kidney disease 4 percent vs. 1 percent; COPD 9 percent vs. 3 percent; prediabetes 17 percent vs. 7 percent; diabetes 16 percent vs. 4 percent; heart disease 5 percent vs. 1 percent; and high blood pressure 43 percent vs. 16 percent. From PPI analysis of 2017-21 Behavioral Risk Factor Surveillance System data. 22 "Medicaid and CHIP Unwinding Planning Efforts Summary of Best & Promising State Practices from CMS/State Discussions April 2022," CMS, April 2022, slide 11, "Theme 3: Workforce Capacity," accessed February 17, 2023, https://www.medicaid. gov/resources-for-states/downloads/state-unwinding-best-practices.pdf; "Strategies States and the U.S. Territories Can Adopt to Maintain Coverage of Eligible Individuals as They Return to Normal Operations," CMS and Medicaid and CHIP Learning Collaboration, November 2021, pp. 13-14; "Address Potential Strains on Eligibility and Enrollment Workforce," https://www. medicaid.gov/state-resource-center/downloads/strategies-for-covrg-of-indiv.pdf. 23 "Consolidated Appropriations Act, 2023," SEC. 5131. Transitioning from Medicaid FMAP Increase Requirements, (tt)(1), accessed March 13, 2023, https://www.congress.gov/117/bills/hr2617/BILLS-117hr2617enr.pdf. 24 "Unwinding and Returning to Regular Operations after COVID-19," CMS, accessed March 13, 2023, https://www.medicaid.gov/ resources-for-states/coronavirus-disease-2019-covid-19/unwinding-and-returning-regular-operations-after-covid-19/index.html. 25 "Public Meeting," January 20, 2022; examples of work in other states can be found in Becky Lopez, "Communicating the PHE Unwinding: How States Are Conducting Outreach and Planning," State Health and Value Strategies, November 2022, https://www. shvs.org/communicating-the- phe-unwinding-how-states-are-conducting-outreach-and-planning/. Fact Sheet 1605002, March 2023 © AARP PUBLIC POLICY INSTITUTE 601 E Street, NW Washington DC 20049 Follow us on Twitter @AARPpolicy on facebook.com/AARPpolicy www.aarp.org/ppi For more reports from the Public Policy Institute, visit http://www.aarp.org/ppi/. https://doi.org/10.2641 i,001: 1 AARP