Much has been written about the enormous task state agencies have faced as they returned to routine operations during the unwinding of the Medicaid continuous enrollment requirement. While the primary focus (rightfully) has been around renewals and the renewal process, states have other eligibility and enrollment operational responsibilities including processing applications for new applicants or individuals trying to reenroll after losing coverage for procedural reasons. Timely processing of applications is not only required, but is also critical to ensuring individual’s timely access to coverage and care.
States must conduct eligibility determinations for applications within 45 days for individuals with MAGI-based eligibility (e.g., children, pregnant individuals, parents, expansion adults). As the unwinding has unfolded, the share of states with 40% or more of Medicaid and Children’s Health Insurance Program (CHIP) modified adjusted gross income (MAGI) applications processed beyond the 45-day threshold has increased – going from one state in March 2023 (AK) up to seven states in March 2024 (AK, DC, GA, MO, MT, NM, and TX). This trend in applications being processed in an “untimely” manner has implications that extend beyond states’ unwinding timelines. Even though all but six states are estimated to have completed their unwinding process by the end of this month, the rebound effect on applications as individuals who lost coverage during the unwinding reapply for Medicaid and CHIP is likely just beginning; backlogs in processing applications will hamper these individuals’ ability to get timely access to coverage and needed care.
CMS appears to have similar concerns with the agency taking several actions related to application processing timeliness over the past few months. On May 9th, CMS issued an informational bulletin and accompanying slide deck reminding states of their obligations to promptly process applications. The materials also highlight key strategies and workflow processes that states can implement to improve application processing times.
