Continuous Coverage Unwind Data Reporting

The Department of Health Care Policy & Financing (HCPF) will be reporting its progress on “unwinding” the continuous coverage requirement to the federal government. HCPF will post these reports on this page and include links to this information in our monthly COVID-19 newsletter.

Connect for Health Colorado will be posting state-based marketplace information according to their reporting schedules.

Returning to Regular Eligibility Operations

HCPF resumed the standard eligibility renewal processes for Health First Colorado (Colorado’s Medicaid program) and Child Health Plan Plus (CHP+) by sending notices in March 2023 to members with May renewal dates. The state opted to take the full 12 months allowed by the federal government to complete renewals for all 1.75 million members, in alignment with our shared goal to Keep Coloradans Covered. This site will share monthly renewal metrics from May 2023 until at least April 2024.

Colorado’s focus is to ensure that those who qualify for our programs remain covered and those no longer eligible are connected to affordable, alternative coverage. Thank you for your vital partnership in achieving this shared goal. Visit KeepCOCovered.com to keep up with changing initiatives, messages and strategies you and your organization can employ, to the betterment of Coloradans, employers, providers and our economy.

While early renewal data and “point in time” data like this is not comprehensive or sufficient to draw trends or conclusions, it can certainly help us determine where we need to focus and refine our strategies to achieve our shared goals and address opportunities. To better understand the PHE unwind data, we looked at history. As you may know, members often lose eligibility for Health First Colorado or CHP+ during the renewal process because they no longer qualify. Commonly, individuals will enroll and be disenrolled from Health First Colorado or CHP+ due to changes in their life circumstances, like losing or gaining a job or changes in their household composition. 

Over the course of the two years prior to the pandemic, an average of 41% of Medicaid members lost coverage - 12% of those losing eligibility for procedural reasons (i.e., they didn’t complete the renewal paperwork submission process) and 29% because they no longer qualified (i.e., they exceeded the income levels for their household size or eligibility classification). People were being disenrolled at a fairly consistent rate with no spikes or dips over the two years. Approximately 20% of Medicaid members lost coverage annually.

As we return to regular renewal processes, we anticipate that more individuals will be disenrolled from our programs because the Colorado economy has returned to pre-pandemic levels. The bulk of those newly enrolling over the last three years did so during the COVID-induced economic downturn. As of August 2023, the state’s unemployment rate is similar to pre-pandemic levels, at 3.1%. This is lower - or better than - the national unemployment rate of 3.8%. We will be actively monitoring the economy throughout this year, given its impact on Medicaid enrollment.

August 2023 Renewals

Based on point in time information, 47% of members with August renewal anniversaries were renewed. Of those renewed, just under half were automatically renewed through advances in processing technology (“ex parte”) made over the last few years, while the other half were renewed after completing their renewal packet. Fifty-one percent (51%) of the individuals up for renewal in August were disenrolled. Of the 51% disenrolled, 15% no longer qualify due to exceeding the income levels for their household size or eligibility classification. 

Thirty-six percent (36%) of those with August renewal anniversaries lost eligibility for procedural reasons such as not completing the renewal paperwork submission process. That figure was 12% prior to the pandemic. Related, only 2% of Coloradans voluntarily disenrolled from Health First Colorado and CHP+ coverage. These factors represent opportunities going forward. We need members to update their contact information so we can reach them with important notifications about their health care coverage, and we need individuals to respond to the renewal packets - complete, sign, and return them. Those who no longer need Health First Colorado or CHP+ coverage can voluntarily disenroll at CO.gov/PEAK or by contacting their county Human Services Department. This will help us better target our outreach efforts to Keep Coloradans Covered.

Renewal Data Over Time

The monthly data reported to the federal government represents a specific point in time and does not take into account individuals who turned in their packets after the deadline who may return to coverage during the 90 day reconsideration period. 

September 2023 marked the end of the first 90 day reconsideration period during the unwind of the continuous coverage. Anyone who has lost coverage because they failed to complete their renewal has an additional 90 days after the end of their renewal period to turn in needed documentation and complete the renewal process; those doing so will not experience a gap in coverage. Those who miss this deadline can reapply to be considered for coverage. To better understand who still qualifies for coverage, it's important to take into account enrollment after the 90 day mark. 

The chart below shows actions taken by members with May 2023 renewals through the 90 day reconsideration period.

*The May submission to CMS was delayed which resulted in the original data submission also being 30 days post-renewal. The original submission for following months are calculated immediately after the month concludes. Had May been submitted on this schedule, the renewed percentage would have been lower and the procedural denial percentage would have been higher.

As you can see in the chart above, the percentage of people renewed grew by 4 percentage points over the 90 day reconsideration period as people completed their renewal packets. This growth brings the renewal percentage to 60%, which is better than our pre-pandemic average. The late actions also resulted in a corresponding drop, or improvement, in the percentage of procedural denials from 26% to 22%.

Members with renewal anniversaries in June and July are still within the 90 day timeframe, but we are already seeing some of these individuals taking late action on their renewals. The June cohort is tracking similarly to the May cohort, with the overall renewal percentage increasing from 48% at the end of the normal renewal period to 54% at 60 days after the renewal period ended. During this same time frame, procedural denials have dropped from 34% to 27%.

Interpreting Colorado’s Data in the National Context

National Trends Reported by CMS

Since each state is approaching the renewal implementation process differently, comparisons across states are not as relevant as looking at prior trends for renewals within that state. That said, on August 31, CMS released information on 37 states which started processing renewals in May. CMS’s national data from May showed an average of 20.3% of applications still pending determinations, which further complicates comparisons given Colorado’s far lower pending application status of 2% or lower. All that said, the national average for those 37 states for May renewals is as follows: 42.1% renewed, 8.6% no longer qualified for eligibility reasons, and 29% no longer qualified for procedural reasons. 

The current national reporting framework (data reported for the prior month and provided within 10 days of the end of the prior month) is publishing data at a time that does not tell the whole story of typical renewal operations. It is more accurate to look at state data after the 90-day reconsideration period, which takes into account late actions taken by members, additional or follow-up data, and for organizations like counties who process eligibility to catch up on backlogs. This is demonstrated by Colorado’s May renewal cohort which initially reported a 56% renewal rate and then rose to 60% when re-run three months later in September. This methodology would also eliminate the current national “pending” figures of 20%+, generating renewal figures far higher than currently reported. After the referenced 90-day period, Colorado’s “pending” rate is about 1%.

Other factors that contribute to an accurate understanding of the data include historical norms and the state’s current economic status. Each state may have different approaches to renewals, so comparisons between them are misleading, which is why we look at past data within our own state. Colorado’s 60% May renewal average is better than its pre-pandemic average of 57%. Our state’s lower unemployment rate, 3.1% compared to 3.8% nationally, also indicates that members are securing jobs and related employer-sponsored coverage, post the COVID-induced economic downturn. That will drive our procedural denials up, as people choose not to respond to a Medicaid renewal outreach when such coverage is not needed.

We are closely monitoring more vulnerable populations. Renewal rates for children are higher than for the general membership: For May, June and July renewals, 69% of children remained enrolled, better than the overall 58% of all Colorado individuals who renewed during the same period. Also, we are not finding racial disparities between people of color and White people: for example, children who identify as Hispanic are being renewed in Colorado at a higher rate than non-Hispanic White children (72% versus 68% from May renewals). We are also closely monitoring rates for members with long term care waiver supports. Procedural denials for this population now track with rates pre-pandemic: 17% then versus 18% now. Less than 1% of members with long term care waiver supports are “whereabouts unknown,” meaning this population is receiving renewal notices.

Shared Goal to Reduce Procedural Denials

Our shared goal is to drive the “procedural denials” back to pre-pandemic levels, largely by collaborating to make sure members actively engage to complete the renewal process. This will be difficult, given that so many Coloradans have gotten new jobs, and with that, employer-sponsored coverage. Those individuals may not be interested in completing paperwork to tell the state they no longer need our safety net coverage programs. 

Members can resume coverage if they still qualify by returning their renewal packet and any missing information to their county for processing within 90 days of losing coverage. Individuals can also reapply for coverage at any time. This is common when individuals realize, after the fact, that they did not complete and return their renewal paperwork as requested or when their life circumstances change, making them eligible again for coverage. Based on pre-pandemic information, on average, about half of the members who had lost eligibility were deemed eligible for Medicaid again within two years. 

The below information is provided to help us address these emerging opportunities and to achieve our shared goal of Keeping Coloradans Covered.

Actions to Reduce Procedural Denials

• Continue Update Your Address Campaign
• Continue Targeted Time to Renew Messaging / Providers, RAEs and partners

Actions to Connect Eligibility Denials to Other Coverage

• Employer Outreach
• Connect for Health Colorado partnership
• #KeepCOCovered

Mitigating Disparities

We are also analyzing data by race/ethnicity, age and geographic region to help identify and mitigate any emerging inequities. Based on the limited information available so far, we have not yet observed any race related disparities in the tracked renewal metrics between white people and people of color, which is good news. That said, it is important to mitigate disparities overall for low income people of color through this important work, and we are indeed focused on achieving that important shared goal.

To avoid health coverage gaps and disparities that historically impact communities of color, LGBTQ+, rural, non-English speakers and people with disabilities, we all need to work together to Keep Coloradans Covered - a key health equity priority. Providers, educators, community leaders and advocates: you are trusted messengers on the frontlines. We ask that you meet with and message to individuals where they are, post flyers, send notifications, make phone calls, talk to members when they’re in front of you, and remind them to open the renewal mail, complete it, and send in the packet by the renewal deadline. Thank you for leveraging your connections with our members to help Keep Coloradans Covered.

Understanding the Data

The monthly report with data on the unwind of the continuous coverage requirement for Colorado has been submitted to CMS and is available on the PHE Unwind Reports page. This page will be updated regularly after data is submitted to the federal government.  

Members of the media, legislators and others can reference these monthly metrics with important context of what they mean to ensure consistent and accurate information is available to the public. HCPF will not be providing “ad hoc” metrics between reporting periods. 

The information below provides critical context for understanding continuous coverage unwind data; it includes:

1. Key terminology
2. Baseline data on Health First Colorado and Child Health Plan Plus (CHP+) coverage before the continuous coverage unwind began;
3. Renewal process timeline;
4. Understanding federal unwind reporting elements; and
5. Frequently asked questions about renewal data.

Key Terminology

There are a few key terms that are helpful to understand the renewal process and reporting.

1. Renewal packet - Prepopulated forms sent to a member to see if anything has changed and request necessary verification to determine whether a member continues to be eligible to receive Health First Colorado or Child Health Plan Plus (CHP+) health coverage. Also referred to as a redetermination or RRR.
    
2. Modified Adjusted Gross Income (MAGI) - Modified Adjusted Gross Income refers to the methodology by which income and household composition are determined for the MAGI Medical Assistance groups under the Affordable Care Act. These MAGI groups include Parents and Caretaker Relatives, Pregnant Women, Children, and Adults.
    
3. Non-MAGI - Low-income individuals may qualify for medical assistance if they do not meet the MAGI criteria above, but do meet one of these criteria: age 65+, blind, individuals with disabilities by Social Security Administration standards. This group is referred to as “Non-MAGI.”
    
4. PEAK - an online portal where Coloradans can apply for and manage several benefits including food assistance, cash assistance, transportation, and health care.
    
5. Procedural denial - This definition varies by state due to differing eligibility processes. In Colorado, this refers to the number of Health First Colorado or CHP+ members who were found to be no longer eligible for coverage in the reporting month for reasons such as: 1. did not respond to the renewal packet/failure to complete the renewal process, 2. failed to provide verification, 3. did not sign their renewal packet, 4. whereabouts are unknown.
    
6. Ex Parte - “Ex parte” refers to a process that states use to automatically renew members based on recent information already on file. This information is reported by members and/or available from other data sources.
    
7. Pending application - an application that has been submitted but has not yet been fully processed.

Colorado’s Medicaid Population Before Continuous Coverage Ended

Source: Annualized data from the last full fiscal year before continuous coverage unwind began, July 2021-June 2022.

*Adults age 65 and older includes people partially eligible for Health First Colorado.

Due to rounding, percentages may not total 100%.

Renewal Process Timeline

Each state can take a different approach to unwinding the continuous coverage requirement. Colorado has chosen to take the full 12 months (14 months including noticing) to complete the unwind of the continuous coverage requirement to align with a member’s existing renewal month.  For details on how the renewal process in Colorado works, including overviews, sample notices and videos visit the PHE Planning Resource Center. Members' frequently asked questions about the process are available at healthfirstcolorado.com/renewals.

Expand Graphic

Note: These numbers are by household. More than one member can make up a household. Individual reports will indicate if the information is by household or by individual. Most reporting is at the individual level.

Understanding Federal Reporting Requirements

Federal Reporting Elements Overview

All states will be required to report the following data elements to the federal government as part of qualifying for enhanced federal matching funds during the unwind period as outlined in the Consolidated Appropriations Act.

 

Reporting Element	Definition for Colorado
Total number of Medicaid and CHIP beneficiaries for whom a renewal was initiated.	In Colorado, this is Health First Colorado and CHP+ members whose renewal process started in the reporting month.  Colorado sends notices 60-70 days in advance of renewals being due. So members with renewals due in May began receiving notices in March.
Total number of Medicaid and CHIP beneficiaries for whom Medicaid and CHIP coverage was renewed.	In Colorado, this is Health First Colorado and CHP+ members who were renewed in the reporting month, including ex parte, paper, and PEAK renewals.
Of the Medicaid and CHIP beneficiaries whose Medicaid and CHIP coverage was renewed, those who were renewed on an ex parte basis.	Colorado uses data from SNAP and other sources to help auto renew members through the ex parte process (defined above in Key Terms). Members who are automatically renewed do NOT need to take action to keep their coverage and will receive a “Notice of Action” letter showing they are approved for coverage. Members may also receive a letter after they are renewed asking if their income information is correct. They must respond to this letter to continue qualifying for coverage. Ex parte is done at the state level, not at a county level. Ex parte rates are available statewide only.
Total number of individuals whose coverage for Medicaid or CHIP was terminated.	In Colorado, this refers to the number of Health First Colorado or CHP+ members who were found to be no longer eligible for coverage in the reporting month.
Total number of individuals whose coverage for Medicaid and CHIP was terminated for procedural reasons.	In Colorado, this refers to the number of Health First Colorado or CHP+ members who were found to be no longer eligible for coverage in the reporting month for reasons such as: 1. did not respond to the renewal packet/failure to complete the renewal process, 2. failed to provide verification, 3. did not sign their renewal packet, 4. whereabouts are unknown.  HCPF’s communications and outreach with health plan and other partners focuses on reminding individuals they need to take action when their renewals are due to ensure members keep their coverage if they are eligible. Messaging was added to the renewal envelopes - URGENT - PLEASE REPLY - to further emphasize the need to take action. Public Service Announcements, posters, toolkit materials and earned media will help raise awareness. Partner efforts to encourage members to update their contact information are also designed to mitigate procedural denials.
Total number of beneficiaries who were enrolled in a separate CHIP.	In Colorado, this refers to the number of Health First Colorado members who were up for renewal that qualified and were enrolled in CHP+ coverage in the reporting month.
For each state call center, total call volume for the reporting month.	From the Medicaid Customer Contact Center (MCC), this refers to the total call volume for the reporting month.
For each state call center, average wait times.	This refers to the average time a caller waits before the call is answered.  Colorado will be reporting metrics from our Medicaid Customer Contact Center (MCC).
For each state call center, average abandonment rate.	This refers to the rate of callers to call centers that drop off before the call is answered. Colorado will be reporting metrics from our Medicaid Customer Contact Center (MCC).

Monthly Unwinding Data Report

The below chart outlines monthly federal reporting elements on the Centers for Medicare and Medicaid Services (CMS) Unwinding Data Report and a description of what those data elements mean.