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Continuous Coverage Unwind Data Reporting

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Public Health Emergency Planning

Continuous Coverage Unwind Data Reporting

The Department of Health Care Policy & Financing (HCPF) is reporting its progress on “Unwinding” of the Public Health Emergency Medicaid continuous coverage requirement (PHE Unwind). Each month, data is submitted to CMS and is available on the PHE Unwind Reports page. Connect for Health Colorado also posts state-based marketplace information, according to their reporting schedules.

PHE Unwind Summary

  • The COVID-induced economic downturn caused hundreds of thousands of Coloradans to lose their jobs and with them, their employer sponsored health benefits. Health First Colorado (Colorado’s Medicaid program) rosters grew by 45%, the 2nd highest percent growth in the nation for a Medicaid expansion state. We should all be proud that Coloradans were able to connect to our safety net coverage programs when they needed them.
     
  • While Colorado processed Medicaid and Child Health Plan Plus (CHP+) member renewals throughout the pandemic, members did not lose coverage if they were no longer eligible because of the federal continuous coverage requirement.
     
  • When the federal government called an end to the public health emergency 3+ years later, Colorado had to review everyone enrolled in Medicaid to determine if they still qualified. (We refer to this 12 month period of redetermination after the end of the PHE as the “PHE Unwind”).
     
  • HCPF and its contracted partners outreached more than 2 million times via text, email, mailings and phone calls to over 500,000 Colorado households to educate on what they needed to do to maintain their coverage. This outreach was in addition to a collaborative campaign with our partners who shared our toolkit messaging and a statewide Public Service Announcement campaign in English and Spanish to raise awareness of the need for Medicaid and CHP+ households to renew their coverage and update their contact information.
     
  • We took the time CMS provided - 12 months or 14 months including noticing - to do so. Notices began in March 2023 for members with renewals due in May 2023, while the last group of renewals in the PHE Unwind were due in April 2024. We aligned with existing member renewal dates to maintain member action consistency, to return to normal renewal processes in an equitable manner, to mitigate impacts to county and eligibility staff workloads, and align with tapering federal funding available to cover individuals during the PHE Unwind.
     
  • The assumption was Medicaid and CHP+ would return to prepandemic enrollment levels through the Unwind, and that is happening overall (about the same number of members are disenrolling during the PHE Unwind as were enrolled during the PHE). PHE Unwind renewals and disenrollments are within 3% of prepandemic norms: 57% prepandemic renewal rate vs 54% during the PHE Unwind. 41% prepandemic disenrollments vs. 44% during the PHE Unwind. 
  • Colorado’s strong economy (more open jobs than people to fill them), wage increases, low unemployment rate, and related factors influence the percent of people renewed and disenrolled. When wages are increased and the unemployment rate is low, less people will requalify for Medicaid and CHP+ at their renewal.
     
  • Accurate comparisons between states can not occur until all states' Unwinding processes are complete, all pending applications are processed (Many states have between 20-25% of their renewal applications pended, while Colorado has about 8%), the 90-day reconciliation timeframes have elapsed, and all final reporting is available. As the Unwind period concludes and reporting is final, we are identifying which states are comparable to Colorado given economic conditions in those states, and what we can continue to learn to evolve and advance our processes.
     
  • We are also analyzing changing coverage patterns with data available through our systems and the All Payer Claims database (APCD). This data is not complete but provides some insights.
    • About 33% of those who were initially disenrolled from Health First Colorado during the PHE Unwind returned to Medicaid or CHP+ coverage. That compares to 42% returning prepandemic.
    • From what we know now with APCD data through December 2023, about 25% of people disenrolling from Medicaid have other insurance. 17% have Commercial coverage, 5% enrolled into Medicare, and 2% enrolled in an Individual plan through the Connect for Health Colorado Exchange. We do not have insights into the health coverage status of the remaining 42%, but we will have more robust APCD data and therefore more insights in late 2024.
    • Additional surveys are being completed to better understand barriers to accessing coverage. We know that Colorado Medicaid is very affordable, with no premiums, deductibles or copays.
       
  • Keep Coloradans Covered remains a focus, with ongoing improvements to Medicaid renewal processes and ex parte automation (up to 59% from 33%, 67% MAGI), collaborations with employers and other partners to raise awareness of all coverage options to connect Coloradans to the affordable coverage for which they qualify.

Colorado’s Approach to Unwind

The continuous coverage requirement locked individuals into coverage during the COVID-19 public health emergency (PHE).  At the conclusion of the PHE, the federal government required all states to return to normal eligibility operations and review eligibility for members enrolled in Health First Colorado (Colorado's Medicaid program) and Child Health Plan Plus (CHP+) within 12 months.

HCPF and its contracted partners outreached more than 2 million times to over 500,000 Colorado households to help members understand what they needed to do to retain Medicaid or CHP+ coverage, if that was their goal. The outreach leveraged health plan partners, providers and others to reach members via email, phone, text messages and mailings based on member communication preferences when it was their time to renew.  Along with a statewide PSA campaign in English and Spanish, community partners accessed and helped distribute materials in 11 languages to raise awareness of renewals and encourage members to update their addresses. Thank you to the many community partners, advocates, health plan and other partners who did their part to help further raise awareness of the renewal process and for your direct member engagement throughout the renewal cycle to achieve shared goals.

Colorado opted to take the full 12 months (14 months including noticing) to review individuals enrolled by their renewal anniversary.  This approach aimed to reduce member disruption and increase renewal results once the PHE Unwind began by continuing to align with Colorado’s ongoing practice to renew on a member’s coverage anniversary date, which Colorado continued throughout the PHE. The approach also ensured an equitable means of returning to business as usual renewal processing. It further recognized the impact to county and eligibility partner workload, given Colorado’s state supervised, county administered structure.

The twelve-month approach also aligned with federal funding allocated to states to finance the cost of coverage during the PHE Unwind.

Enhanced Federal Matching Funding Reductions

5% April - June 2023
2.5% July - September 2023
1.5% October - December 2023

States have approached the PHE Unwind differently, making state to state comparisons difficult. For example, Colorado has a much lower “renewal application pending” rate than most states (about 8% are pending in CO compared to more than 20% for some states).  Pending applications must still be processed and are not reflected in other states’ renewal or disenrollment data. Accurate comparisons between states can not occur until all states' Unwinding processes are complete, all pending applications are processed, the 90-day reconciliation timeframes have elapsed, and all final reporting is available.

Returning to Prepandemic Enrollment Levels

Colorado’s enrollment grew by 45% during the pandemic, a higher percentage than any other Medicaid Expansion state except for Hawaii, based on the Department’s research. During the pandemic, the Department worked collaboratively with stakeholders and the Colorado Department of Labor and Employment (CDLE) to outreach to individuals who lost their jobs and therefore their employer-sponsored coverage due to the COVID-induced economic downturn to help them enroll into Health First Colorado. Thank you CDLE for your continued support during the PHE Unwind - for reminding employers to help connect employees who no longer qualified for Medicaid back onto employer-sponsored health insurance.

Enrollment has dropped consistently each month through the twelve-month PHE Unwind. As of April 2024, enrollment has nearly reached prepandemic levels, reflecting the end of the Colorado’s PHE Unwind period, May 2023 to April 2024. However, the 90-day reconsideration period will continue through July, with reporting available in August. During that period, members will submit renewal information late; that information will be used to re-enroll an estimated 7% of the disenrolling members back onto Medicaid.

Enrollment is more closely resembling prepandemic norms, where historically eligible members with higher medical needs stay covered, while the vast majority of those who enrolled during the COVID-induced economic downturn - a generally healthier population - no longer qualify. 

For each of the 3 years prior to the pandemic, Health First Colorado and CHP+ membership had been declining in aggregate by about 3% annually, reflecting the strong Colorado economy. During the PHE, Medicaid and CHP+ membership grew by about 550,000. Through the PHE Unwind, we continue to track with the February 2024 estimate of a net enrollment reduction of 519,000 members.

With the exception of the Long-Term Services and Supports (LTSS) population, we will know the final enrollment figures in August as the final 90-day reconsideration period reflecting April renewals comes to an end. The Department has worked collaboratively with counties to expand the processing timelines for members eligible for LTSS, given their unique needs, the complexities associated with the LTSS renewal process, and the transformative efforts currently underway that are impacting members, providers, and case management agencies.

Colorado’s Economic Environment and Enrollment Impacts

There are a variety of strong Colorado economic factors that are impacting Colorado’s eligibility redetermination results.

Since Health First Colorado and Child Health Plan Plus (CHP+) are income-based programs, wage increases can have a direct impact on an individual’s eligibility as well as Colorado’s overall program enrollment.

  • Colorado’s minimum wage grew by 20% from 2020-2024 ($12.02 to $14.42). Our minimum wage is higher than most other states (8th highest in nation). At the same time, Denver’s minimum wage increased by 42% from $12.85 in 2020 to $18.29 in 2024.

Second, Colorado’s unemployment rate has also been stronger throughout the PHE and the PHE Unwind, which will cause more people to rise off of Medicaid than other states. In February 2020, the prepandemic unemployment rate in Colorado was 3.2%, while the national unemployment rate was 3.5%. In May 2023, at the start of the PHE Unwind, Colorado’s unemployment rate was 3.1% in comparison to the higher national unemployment rate of 3.7%. As of April 2024, our state’s unemployment rate of 3.7% continues to perform better than the national unemployment rate of 3.9%. Many states are still over 4% - like CA, NY, IL, PA, MI, WA. That means less individuals will requalify for coverage in Colorado compared to other states.

To qualify for Medicaid, a single person has to make less than about $20k annually and a family of four has to make less than about $40k. For children to be eligible for CHP+, household income can be about double those figures. Given that criteria, Coloradans who found a new job as Colorado’s economy bounced back are less likely to qualify for Medicaid through the PHE Unwind.

Pending Renewals, Economic Factors and Pandemic Growth Comparison 

Subset of States that Expanded Medicaid

LocationPend % as of March 2024Minimum Wage 2024Unemployment Rate March 2023Medicaid FMAP 2025Medicaid Enrollment Feb 2020 - March 2023
Arizona514.353.565%33%
California2216.004.450%27%
Colorado814.422.850%41%
Connecticut715.694.050%22%
Delaware1213.254.460%37%
Hawaii1514.003.559%45%
Illinois214.004.451%29%
Kentucky237.253.871%24%
Maine2014.152.662%37%
Maryland515.002.750%29%
Massachusetts615.003.550%30%
MichiganNA10.334.165%28%
MinnesotaNA10.852.851%34%
New Jersey2415.133.550%35%
New Mexico2312.003.572%18%
New York316.00/15.004.150%30%
North CarolinaNA7.253.565%32%
OregonNA14.204.459%38%
Pennsylvania147.254.255%29%
Rhode Island414.003.156%29%
Washington016.284.550%27%

Enrollment Changes by County and Enrollment as a Percent of Population

To better understand the local impact of the end of continuous coverage and the PHE Unwind, the graph below depicts the percentage of the population, by county, that was enrolled in Medicaid or CHP+ prepandemic (January 2020 blue bar), directly before PHE Unwind began (May 2023 which was the peak of enrollment, rust colored dot) and at the end of PHE Unwind (April 2024 tan dot).

Medicaid and CHP+ Member Enrollment as Percent of County Population

 
CountyStart of PHE, January 2020Start of Unwind, May 2023Current Enrollment, April 2024Enrollment Difference (Jan 2020 minus April 2024)
Adams27%39%28%-1%
Alamosa44%54%42%2%
Arapahoe21%32%23%-2%
Archuleta26%35%25%1%
Baca41%52%39%1%
Bent33%42%32%1%
Boulder15%22%15%0%
Broomfield10%16%11%-1%
Chaffee20%28%20%0%
Cheyenne30%39%32%-2%
Clear Creek15%23%14%1%
Conejos45%55%43%2%
Costilla57%70%53%4%
Crowley26%31%24%2%
Custer20%27%20%0%
Delta32%42%30%2%
Denver28%37%28%0%
Dolores29%37%29%0%
Douglas8%12%8%-1%
Eagle12%20%13%-1%
El Paso24%33%23%1%
Elbert12%16%12%1%
Fremont28%36%28%1%
Garfield22%32%22%0%
Gilpin18%25%18%0%
Grand12%19%13%-1%
Gunnison19%26%16%3%
Hinsdale20%25%20%0%
Huerfano44%51%38%6%
Jackson24%28%16%7%
Jefferson16%22%16%0%
Kiowa32%44%35%-3%
Kit Carson31%41%29%1%
La Plata22%31%21%1%
Lake22%32%20%2%
Larimer18%25%18%0%
Las Animas42%52%37%5%
Lincoln25%37%26%0%
Logan25%34%26%-1%
Mesa28%37%27%1%
Mineral20%28%21%-1%
Moffat28%39%28%0%
Montezuma37%48%36%1%
Montrose29%40%29%1%
Morgan30%43%30%0%
Otero43%55%43%0%
Ouray14%19%13%1%
Park18%24%17%1%
Phillips25%33%25%-1%
Pitkin9%14%8%1%
Prowers41%55%42%-1%
Pueblo40%50%39%1%
Rio Blanco22%31%22%0%
Rio Grande39%50%37%2%
Routt13%19%11%3%
Saguache36%49%38%-2%
San Juan26%32%21%5%
San Miguel13%22%13%0%
Sedgwick31%41%33%-1%
Summit12%20%13%-1%
Teller22%30%21%2%
Washington27%37%27%-1%
Weld21%31%23%-2%
Yuma29%40%29%0%
 

Overall, our enrollment is higher than prepandemic by about 50,000 members. The detailed chart below shows the 33 counties that saw a net increase in their enrollments, and the 31 that saw net decreases.

Medicaid/CHP+ Enrollment January 2020 to April 2024

County TypeTotal Lost or Gained
31 counties had a reduction-10,358
33 counties had an increase60,081
Net change among all counties49,723

Renewal and Disenrollment Historic Comparison

We have also been tracking PHE Unwind data compared to historic norms (based on 2018 and 2019 calendar years). That analysis shows that the PHE Unwind renewals are tracking within 3% of prepandemic norms (54% vs 57%), while disenrollments are within 3% of prepandemic norms (44% vs 41%).

Importance of the 90-Day Reconsideration Period, Plus Emerging Data

The monthly data reported to the federal government represents a specific point in time within eight days after the close of the respective month. However, we know from historic trends that many members who still qualify leverage the 90-day reconsideration period to submit their renewal late to remain covered. Again, the reconsideration period provides an additional 90 days for individuals to turn in needed documentation or a completed renewal. The chart below shows renewals by month, incorporating the impact of the 90-day reconciliation period (gold bar). It also shows what was reported to CMS (blue bar, within 8 days of the end of the month) as well as progress 30 days after the end of the month (orange bar) and after 60 days (gray bar). The national averages are represented by the horizontal dotted line.

This chart shows that the percentage of members renewed grew by an average of 7 percentage points and as much as 10 percentage points (removing May, which included a late first submission) over the 90 day reconsideration period as people continued to complete and turn in their renewal packets.

Emerging Colorado disenrollment analysis also indicates that 33% of the Medicaid population disenrolled during the PHE Unwind has already requalified for Medicaid and has been re-enrolled. That compares to 42% returning prepandemic.

 
 

Historic Renewal and Disenrollment Comparisons

Colorado’s average renewal rate of 57% prepandemic (calendar years 2018 and 2019) closely aligns with Colorado’s PHE Unwind average renewal rate of about 54% (based on May 2023 through January 2024 data, including the 90-day reconsideration period). This means Colorado’s PHE Unwind renewal rates after more than a 3-year pause are within 3% of prepandemic norms.

Likewise, Colorado’s average disenrollment rate of 41% prepandemic (calendar years 2018 and 2019) also closely aligns with Colorado’s PHE Unwind average disenrollment rate of about 44% (based on May 2023 through January 2024, including the 90-day reconsideration period), meaning Colorado’s PHE Unwind denial rates after more than a 3-year pause are within 3% of prepandemic norms.

That said, we are not satisfied with prepandemic norms, so we are implementing short-term and long-term solutions to improve the overall eligibility process, with an initial focus on members with Long-Term Services and Supports (LTSS). Longer term, HCPF, CDHS and the counties are collaborating on an emerging report, directed by SB 22-235, targeting a November submission to the general assembly. This report outlines recommendations for process, technology, wage rates improvements and more - all intended to improve the eligibility process to the betterment of members, providers, counties, and state departments. We appreciate your partnership on this important work.

Improving Eligibility Performance - Understanding Procedural Denials

A top priority for improving eligibility performance is to reduce inappropriate procedural denials. Procedural denials are administrative denials for issues other than income and other eligibility requirements. It also includes individuals voluntarily opting out of Medicaid coverage because they no longer need safety net coverage.

Our data indicates that our procedural denials are higher than historic prepandemic levels, while our income-based and other qualified eligibility-based denials are far below historic (about half). This is not unexpected; in fact, we expected that individuals who regained employment and the related employer-sponsored coverage during the PHE, would not consistently respond to our renewal inquiries, or our requests to verify income. For this reason, a far higher procedural denial rate than historic should be expected after a three year pause.

Procedural denials also result from individuals who did not appear to meet eligibility income criteria through the ex parte process failing to verify or update their income when a renewal packet is sent. This will make Colorado’s procedural denials appear higher, though the root issue is that individuals are over income and simply not verifying this fact - not responding to renewal inquiries. The bar chart below illustrates that procedural denials after the 90-day (gold) bars are averaging about 25%.

Ex Parte Automation Improvements

Ex parte is the automation of renewal approvals. Increases in ex parte automation performance improves the member experience, reduces county workload and reduces inappropriate procedural denials. In April, HCPF implemented a process to increase the auto-renewal of all Coloradans with historic incomes less than 100% of the Federal Poverty Level when there is no conflicting data in our electronic data sources. We project this advance will increase our ex parte rates on income-based individuals (MAGI) by about 5 percentage points.

Overall, our automated renewal ex parte rates have increased from an average of about 33% through the PHE Unwind to 59% overall for renewals that were due in May 2024 and 67% for MAGI households, as we approach June 2024 renewals.

Coverage Transitions - Preliminary Insights

Colorado is analyzing health insurance coverage patterns based on our All Payer Claims Database (APCD) to better understand if formerly qualified Medicaid or CHP+ members have transitioned to other coverage. While more insights will be coming later this year, preliminary analysis of APCD data through December 2023 of Coloradans disenrolling from Health First Colorado during the unwind shows:

  • 33% re–enrolled into Medicaid
  • 25% have other insurance 
    • 18% Commercial
    • 5% Medicare and 
    • 2% Marketplace

The status of the remaining 42% is unclear as we do not have data or insights. The available APCD data has gaps and does not reflect a health plan that hasn’t submitted data yet as well as the impact of self-insured employers who are not required to report their data to the APCD. Self-insured claims are estimated to represent half of the total commercially insured lives in Colorado according to the APCD Annual Report. In addition, this data is only through December 2023, reflecting 8 months of the unwind. Last, Medicare data insights are also limited.

When analyzing Medicaid claims data for those who disenrolled we found that 33% did not utilize our services at all between June 2022 and May 2023.

The Department is working to better understand the gaps in our current data, both for those who re-enrolled in Medicaid, and why there was a break in coverage. For those who disenrolled from Medicaid, we are seeking to understand if they have other coverage and if not, why. Gaining these insights is a top priority for the Department so that we can identify ongoing opportunities and best practices to Keep Coloradans Covered.

Supporting Member Renewals

Improvements Implemented:

  • Enhanced Member Outreach
  • Improved Automatic Renewals
  • Shortened Renewal Packet
  • Online Renewal Upgrades
  • Improved Contact Info. and system changes to reduce Whereabouts Unknown denials
  • Pause LTSS terminations for all reasons for two months (60 days) past the member’s original termination date (except for death and relocation out of state).
  • NEW Webpage: Stabilizing Long-Term Services and Supports (LTSS)

Improvements in Process (requires system updates and federal approvals):

  • Automatically renew members earning less than 100% FPL when third party data sources return no information ($1,215/month individual, $2,500/month family of 4)
  • Automatically backdate coverage for those who renew during reconsideration period
  • Enhanced outreach during reconsideration period
  • Ongoing strategic advances in collaboration with counties and further improving member letters

Transitioning to Other Coverage and the Associated Risks

Our shared goal has been to Keep Coloradans Covered. We are thankful for the many contracted partners, advocates, providers, insurance carriers, employer chambers, sister state agencies and other community partners who have collaborated on this important work.

The most popular types of coverage most Americans connect to outside of Medicaid are Employer Sponsored, Medicare and Individual coverage. Since losing Medicaid coverage is a “qualifying event,” one can seek other coverage without having to wait until “open enrollment” through an employer, Medicare, or the Connect for Health Colorado marketplace exchange.

Prepandemic, and typically, about half of Coloradans get their health insurance coverage through Employer sponsored coverage. During the Public Health Emergency, most people enrolled into Medicaid after losing their job (and their employer sponsored coverage) during the COVID-induced economic downturn. So, the vast majority of people disenrolling from Medicaid during the PHE Unwind should be returning to employer-sponsored coverage. Unfortunately, most of those disenrolling from Medicaid throughout the PHE Unwind did so outside of their employer’s typical open enrollment period, which is generally 6-8 weeks of the year, meaning those employees do not have the support they typically would have to enroll in coverage. Further, if the employee missed the window to enroll after their qualifying event, they may have been prohibited to do so by their employer. 

Recognizing this risk, CMS recommended that employers extend their special enrollment period (SEP) from 60 days to 1 year in a federal government’s letter to employers, plan sponsors and issuers. To mitigate the negative consequences of individuals being uninsured, and to help Coloradans navigate back onto employer-sponsored coverage, HCPF has created specific tools for employers and their HR departments. They are available at KeepCOCovered.com and Downloadable Resources: #KeepCOCovered. CDLE further partnered to remind employers to help navigate their employees who no longer qualify for Medicaid back onto employer-sponsored health insurance, in collaboration with our shared efforts to Keep Coloradans Covered.

Those over 65, and not actively working, should be enrolling into Medicare. That might include Medicare Advantage, available through commercial carriers or traditional Medicare.

Others may need to purchase individual or family coverage. The most affordable way to do so is through Colorado's Connect for Health marketplace exchange, which provides many options for health coverage as well as federal subsidies to make individual and family premiums and coverage more affordable. To help disenrolling Coloradans to connect to the subsidies available through Connect for Health, HCPF provides customized files to Connect for Health Colorado to enable their outreach to disenrolling Medicaid members and to make sure those individuals know they are eligible for a subsidy.

Coverage Options for Coloradans

CHP+: HCPF is auto-enrolling eligible kids as part of the Medicaid redeterminations process. CHP+ enrollment has gone from a low of 45K in May 2023 to 83K in March 2024, even above prepandemic enrollment of 79K.

Employer Sponsored Insurance: More Coloradans get their coverage through employer sponsored plans - about 50% - than any other type of coverage. Employers have annual open enrollment periods, opportunities to sign up when new employees are hired. Some employers may also offer special enrollment periods.

Family Member Employer Sponsored Coverage: Spouses, dependents, and children up to age 26 can be on their family’s employer plan.

Connect for Health Colorado: The state’s ACA marketplace. Premium and cost-sharing subsidies are available below certain income thresholds. 

OmniSalud: Coverage option for people who are undocumented or have DACA status. Immigration status not asked as part of application. Less than 150% FPL may qualify for subsidies. Program has an enrollment cap - that enrollment has been met for this year.

Medicare: Primarily for people over age 65. Penalties associated with late enrollment. People can qualify for Medicare and Medicaid (duals), where Medicare is main payor and Medicaid is payor of last resort and primary payor for long-term services and supports.

To apply for health coverage or programs, visit: colorado.gov/health

Understanding the Affordability Transition Challenge

Medicaid provides robust coverage for zero premiums, zero deductibles and zero copays, except for the inappropriate use of the emergency room.

This is not the case with employer-sponsored insurance. We are fortunate that Colorado has made health care affordability a top priority, so we are in a better place than other states. Still, there is still a wide gap between Medicaid affordability and employer-sponsored health insurance affordability.

That reality is a significant influencer in the household budget decisions many individuals and families have to make as they choose between paying for health insurance coverage or other basics like rent, groceries, a car payment, gas or utilities. 

In fact, our most recent insights into those disenrolling from Medicaid indicate that the older one is, the more they are prioritizing the purchase of health insurance while those who are younger are not connecting to coverage at the same rate.

Point in Time: May Renewal Insights

Based on point in time information reported to the federal government eight days after the close of the month, 76% of Medicaid members were renewed in May, with 50% being automatically renewed through advances in ex parte processing technology. The other 26% were renewed after completing their renewal packet. 7% were disenrolled due to income or other eligibility requirements, while 13% were disenrolled for procedural reasons. This includes 5% who voluntarily disenrolled, 64% failed to return their renewal, 23% who failed to provide verification.

The two tone green chart below illustrates, through the bars on the right, that the average 25% PHE Unwind procedural denial rate, after the 90-day reconsideration period, is about double historic norms. Related, the middle bars illustrate that current denials due to income and other eligibility criteria are about half of historic; this is largely because individuals are not verifying their “over-income” information as part of the current PHE Unwind renewal process. If that verification information was submitted, the income based eligibility denial would go up and the procedural denial rate would go down. Added together, the PHE Unwind disenrollment percent of 44% is within 3% of the 41% rate, prepandemic, as reflected in the bars on the left.

Reducing Inappropriate Procedural Denials

Our shared goal continues to be to mitigate procedural denials on those members who should be retaining Medicaid coverage. Below are short-term, waiver-related, and long-term solutions in process to do just that. We are very appreciative of all who are collaborating with us to mitigate inappropriate procedural denials.

Short term, Colorado has implemented several state-specific and federal measures to mitigate procedural denials. We have shortened the renewal packet by 33% and created an escalation process for individuals who need the Department’s assistance when the standard eligibility processes are not creating an accurate member outcome. We continue to increase ex parte eligibility automation performance; in fact, our automated renewal ex parte rates have increased from an average of about 33% through the PHE Unwind to 59% overall in May and 67% for MAGI members, as we approach June renewals. We are also focused on improving PEAK capabilities, the digital tool available via a telephone application and computer application that helps members electronically process a renewal or new application. We have also worked with counties to create an Overflow Processing Center (OPC) to assist counties who find themselves in a backlog situation and have also created a Return Mail Center to track down and process address changes to make sure covered individuals receive Medicaid and CHP+ communications. At the same time, we are actively working on improving eligibility correspondence clarity, with most of the standard letters updated by August and the balance by October 2024.    

Further, in February, we implemented a waiver to permit the designation of an authorized representative for the purposes of signing an application or renewal form via the telephone without a signed designation from the applicant or member and in April, we implemented a process to auto-renew all Coloradans with historic incomes less than 100% of the Federal Poverty Level.

Recognizing the complexities associated with Medicaid renewals for people with disabilities, last September we implemented a 60-calendar-day extension to complete the renewal process, available for our vulnerable populations, including long-term care (LTC), members on waivered services, and buy-in recipients who have not returned their renewal packet on time. This extension provides 5 months for this population to process their renewals.

In complement to these short-term solutions, we are collaborating with counties on longer term strategic advances that improve the overall eligibility process and reduce gaps in coverage. First, HCPF, the Colorado Department of Human Services and the counties are collaborating to advance three unique plans by the end of Fiscal Year 2024-25. This includes a report due to the legislature in November 2024 that provides recommendations for operational, systemic and funding changes to better equip the counties over the long term to serve the eligibility needs of the state and our safety net programs. Second, the Executive Steering Committee for the Colorado Benefits Management System (CBMS), the state-owned eligibility system, will complete a long-term vision and plan to improve CBMS, which the committee will then act upon to the betterment of those served. Third, a Joint Agency Interoperability (JAI) plan has been approved by HCPF, CDHS and the counties and is being implemented to create one work and document management system, to be used by all counties, that allows for work to be portable to improve overall eligibility performance. 

We are also working on implementing an additional waiver to automatically (without member action) reinstate members back to their renewal date when they submit and are approved during their 90-day reconsideration period (Date TBD). Recently, CMS extended flexibilities (or waivers) through June 2025 to assist states with processing renewals, which is welcome news.  

Longer term, we are working with CMS to make several of these waivers permanent, which include the following:

  • Renew Medicaid eligibility based on financial findings from the Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), or other means-tested benefit programs. 
  • Delay procedural terminations for beneficiaries for one or more months while the state conducts targeted renewal outreach, which is currently operational for long-term care renewals.
  • Renew Medicaid eligibility for individuals through Ex Parte (automated renewals) with income at $0 (currently operational) or below 100% Federal Poverty Level (operational in April) when no data is available through electronic interfaces.
  • Partnering with National Change of Address (NCOA) Database and United States Postal Service (USPS) In-State Forwarding Address to Update Beneficiary Contact Information.

Mitigating Disparities

We are also analyzing data by race/ethnicity, age and geographic region to help identify and mitigate any emerging inequities. Ongoing analyses are not indicating race related disparities in the tracked renewal metrics between white people and people of color.

To avoid health coverage gaps and disparities that historically impact communities of color, rural, people with disabilities, LGBTQ+, and non-English speakers, we all need to work together to Keep Coloradans Covered - a key health equity priority. Thank you for your continued partnership on this important health equity work.

Help Us Keep Coloradans Covered

Our top priority continues to be to Keep Coloradans Covered. Thank you for your active engagement with members, community partners, and advocates leading up to and during the PHE Unwind period and for your continued dialogue to improve the renewal process, as we seek for continuous improvement to our eligibility processes as a best-practices approach. 

Please continue to employ our toolkits to help members complete the renewal process or transition to other affordable health coverage. These toolkits are available in the top 11 languages spoken by our members. Resources for partners and employers to assist in this process are also available in the PHE Resource Center. And thank you again for your partnership in outreaching Health First Colorado and CHP+ members to complete their renewals. Those who no longer need Health First Colorado or CHP+ coverage should voluntarily disenroll at CO.gov/PEAK or by contacting their county Human Services Department. This will help all of us more efficiently target our shared outreach efforts to those who should be maintaining Medicaid coverage, going forward.