As Medicaid review continues, many Virginians have lost coverage for procedural reasons

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Since the start of April, nearly 140,000 Virginians have lost Medicaid coverage as part of the state’s return to normal enrollment processes following the end of the COVID-19 federal public health emergency. 

For the past three years, anyone enrolled in Medicaid was allowed to keep their coverage regardless of whether or not they still met eligibility requirements. According to the Virginia Department of Medical Assistance Services’ Medicaid unwinding renewal dashboard, nearly 400,000 enrollees reviewed so far have kept their coverage. 

This “unwinding” process is meant to terminate coverage for enrollees who are no longer eligible due to reasons such as exceeding monthly income limits. However, data from health care nonprofit KFF, formerly known as the Kaiser Family Foundation, shows 43% of people who had lost coverage in Virginia as of June lost it for procedural reasons other than ineligibility. 

Procedural reasons for termination of coverage include cases when enrollees don’t submit necessary paperwork to the state on time. 

If DMAS doesn’t have enough information to automatically renew an individual’s coverage, the agency may mail him or her a renewal package asking for additional information. Individuals who do not complete and submit the package within 30 days will have their coverage terminated for failing to renew.

However, Virginia Poverty Law Center analyst Eleanor Sullivan said some Medicaid members have contacted the organization saying they received their renewal package only a few days before the 30-day deadline. This, she said, has made it difficult for them to return the necessary information before their coverage is terminated. 

“We are in the process of asking the state how widespread these mailing delays may be, as they affect Virginians’ access to care,” Sullivan said. 

U.S. Secretary of Health and Human Services Xavier Becerra urged the nation’s governors in a June 12 letter to take advantage of federal flexibilities to minimize avoidable coverage losses, especially for people who are still eligible. 

“Nobody who is eligible for Medicaid or the Children’s Health Insurance Program should lose coverage simply because they changed addresses, didn’t receive a form, or didn’t have enough information about the renewal process,” said Becerra.

Virginia applied for three flexibilities that were approved July 27 by the federal Centers for Medicare & Medicaid Services, which oversees state and federal Medicaid benefits. These flexibilities allow enrollees to designate an authorized representative to assist them with completing their renewal form over the phone, let Medicaid managed care plans help enrollees with the renewal process and reinstate coverage for people who are found to be eligible after losing coverage for procedural reasons. 

Individuals who lose coverage after failing to renew within the 30-day window may still submit their paperwork for renewal during the 90 days following the date that their package was sent. Anyone who renews within that 90-day grace period may have their Medicaid reinstated if they’re still eligible, with coverage being retroactively applied through the date of termination to eliminate any gaps. 

“However, to our knowledge, neither termination notices nor renewal packages mention the 90-day grace period,” Sullivan said. “We are concerned that Virginians who still qualify for Medicaid won’t seek to regain coverage because they are unaware that they can still renew past the 30-day deadline.”

Individuals who lose coverage due to not completing the renewal process also won’t be referred for coverage through Federal Marketplace insurance. 

DMAS did not provide answers to specific questions about the redetermination process and potential delays, but pointed the Mercury to several resources, including help on understanding the renewal calendar and information on the return to normal enrollment. 

An Aug. 9 letter from the Centers for Medicare and Medicaid Services to DMAS stated only 6% of Virginia Medicaid enrollees had had their coverage terminated because of procedural reasons as of May. However, KFF Vice President Robin Rudowitz and research associate Sophia Moreno said that figure was in comparison to the total pool of over 200,000 Virginians whose cases were reviewed at the time and include those who have lost and retained their coverage.

Rudowitz and Moreno said their 43% figure, by contrast, reflects the pool of people who have lost coverage after redetermination. 

According to DMAS’ website, an enrollee who is no longer eligible for Medicaid benefits will receive a letter notifying them of their termination of benefits. If the termination occurs on or before the 16th of the month, their coverage will end on the last day of the same month. If the termination occurs from the 17th through the end of the month, their coverage will end at the close of the next month. 

This story was updated to clarify statements from Rudowitz and Moreno on the percentage of Virginia enrollees who had their coverage terminated because of procedural reasons.