Medicaid Continuous Coverage Unwinding Continues

Pennsylvania is three months into “unwinding” of the Medicaid (Medical Assistance) continuous coverage protections that had been tied to the COVID-19 pandemic. These protections allowed people on Medicaid to keep their coverage even if they were not eligible or didn’t complete a renewal.  These individuals are considered “COVID maintained” because they were kept on Medicaid only because of the COVD era protections.  Since April 1, the Department of Human Services (DHS) has been able to terminate Medicaid for COVID maintained individuals as well as all others on Medicaid.  if they are ineligible or when renewal paperwork is not received.   

As reported previously, DHS is taking a full twelve months to review eligibility of everyone on Medicaid, which means the work of conducting renewals will be spread out. Most Medicaid renewals will occur when they normally would be scheduled. DHS anticipates renewing an average of 300,000 people per month during the 12-month unwinding.   

For those interested in following the unwinding progress, DHS has made available on its website two sets of data on the continuous coverage unwinding.  DHS’s Unwinding Tracker includes statewide, county, and zip code-level data on Medicaid renewals and their outcomes for the 1.3 million individuals in the COVID Mmaintained population described above.  PHLP understands the data is intended to be cumulative but is awaiting clarification on some data discrepancies to confirm the accuracy of what is currently posted. DHS is also posting the unwinding reports it sends to the Centers for Medicaid and Medicare Services (CMS) each month showing the outcomes of renewals for the entire Medicaid and CHIP population. These reports have limitations, as they do not show outcomes of renewals that were due in one month, but not processed until the next.  For example, the April report notes that 124,950 (48%) of the individuals whose renewals were due in April had not yet had their eligibility reviewed.  But the May report does not report the outcomes of those renewals, resulting in a substantial information gap.   

As a result of the gaps in the available data, PHLP has been able to draw few conclusions from the data alone.  However, it does appear that the overwhelming majority of “procedural terminations” – terminations because a renewal or other required documentation was not received by DHS – are among the COVID maintained population.  This likely includes people who moved but haven’t updated their address with DHS and people who know they are no longer Medicaid eligible so did not return their renewal.  It also could include people whose renewals were late due to mail delays and individuals who have struggled to meet renewal documentation requirements.  

PHLP has noted some issues – at least among our clients – that reflect a few challenges in the renewal process. These include: CAOs encountering errors preventing them from putting up eligibility for some Medicaid recipients. Several PHLP clients reported being told by their caseworker that they should not appeal their Medicaid denial, which is an inappropriate interference with the right to a fair hearing to challenge a denial. Others have been informed of their Medicaid termination less than 15 days in advance, resulting in Medicaid being inappropriately terminated before an appeal could be filed.  

As Pennsylvania moves deeper into the Medicaid continuous coverage unwinding over the next months, we will share additional information with readers.  In the meantime, Medicaid recipients are reminded to update contact information and other details with DHS, by calling the Statewide Customer Service Center at 1-877-395-8930 (in Philadelphia call 215-560-7226) and keep an eye out for and respond promptly to letters and renewals from the County Assistance Offices.  Those needing assistance with Medicaid eligibility or appealing a Medicaid termination or denial can contact their local Legal Aid office or PHLP's Helpline at 1-800-274-3258.