Medicaid Unwinding

Individuals and families must meet a variety of eligibility requirements to qualify for Medicaid services. In order to ensure that members continue to meet the requirements, the eligibility of each member is re-determined once a year. Re-determinations occur on a state level, but the requirement for states to complete annual financial reviews is a mandate from the Centers for Medicare and Medicaid Services (CMS). Re-determinations are completed on a continual basis throughout the year, with each member up for re-determination one year after they were last determined eligible for services.

The Kansas Department of Health and Environment (KDHE) utilizes two types of renewals in re-determinations:

Passive Renewals. Passive renewals, also known as auto renewal or ex parte renewals, require no additional action by the member if the information is correct. These renewals occur when KDHE is able to match all eligibility criteria, such as income, against existing data sources. KDHE staff sends the household a letter with the information found and the member only needs to respond if information is not correct; and

Pre-populated Renewals. Pre-populated renewals occur when KDHE is not able to electronically match required eligibility to existing data sources for each member in the household. Any member who does not meet the criteria has to respond to the request for information. In these cases, the system will populate the member’s renewal form with any information they were able to verify and send it to the member in the family who does not meet the criteria to complete. The member is then responsible for completing the form and returning it to KDHE for processing. This results in some members of the household receiving a passive renewal and other members required to respond to KDHE.

All renewals start as passive renewals but become pre-populated renewals when data is not available or it is significantly different than what is currently in the system. Members have approximately 90 days to submit the renewal, which can be completed on paper or online. Renewal forms must be signed and received by the KanCare Clearinghouse timely for the review process to complete.

If the member returns their pre-populated renewal by the deadline, they will stay on Medicaid until a final eligibility determination is made. If a renewal is returned late, the member will lose eligibility. However, if the deadline is missed, members have 90 days to submit the renewal and, if determined eligible, will have eligibility backdated. This is referred to as the “90-day window.”

Medicaid Unwinding

For the past three years, federal law has required states to keep Medicaid members enrolled because of the COVID-19 public health emergency. During that time, Kansas Medicaid (KanCare) did not complete annual re-determinations. Instead, each member’s eligibility was retained without verifying renewal eligibility. This is often referred to as the “continuous eligibility requirement.” As a result, Medicaid enrollment increased from 410,000 to 540,000 members between March 2020 and April 2023.

In December 2022, the federal Consolidated Appropriations Act set April 1, 2023, as the end of the continuous eligibility requirement and states were required to resume re-determinations. This process is referred to as “unwinding.”

Kansas began its unwinding period in March 2023 with members who had an April renewal date. The unwinding process will take place over a 12-month period, with final renewal notices of the unwinding period being sent out in February 2024.

2023 Changes to Medicaid Re-determinations

During the process of unwinding, CMS provided technical assistance to Kansas and a correction was identified that impacts the passive renewal process for households.

When reviewing eligibility of members in the same household, data matches are applied to each person to determine if they meet Medicaid eligibility. Under previous practices, a pre-populated renewal was sent to all members of a household if any of the members did not qualify for a passive review. Under new practices, the pre-populated review is only sent to those individuals who do not meet the criteria for a passive review, and any household members who do qualify for a passive review will be sent a passive renewal form. This change is anticipated to increase the average number of passive reviews each month by 8.0 percent.

Another change made during the unwinding process is the extension of the time members have to return their renewal form. To cut down on the number of forms coming in late due to slower mail process, the original 30-day deadline to return renewal forms was extended to 90 days.