Theis, Lindsey
Lukanen, Elizabeth
Zylla, Emily

State-Based Marketplace Transition Data During the Unwinding (Cross-Post)

The following content is cross-posted from State Health & Value Strategies. Authors: Elizabeth Lukanen, Emily Zylla, and Lindsey Theis, SHADAC

This expert perspective (EP) will be updated by SHADAC experts as additional dashboards/reports go live. Please visit the State Health & Values Strategies webpage for the most recent version of this EP.

Original publication date: August 16, 2023. Updated: January 11, 2024.

As the unwinding of the Medicaid continuous coverage requirement progresses, SHVS is closely monitoring state reporting on the impacts of redeterminations and disenrollments. There is intense interest in data that monitors transitions between Medicaid and Marketplace coverage and, more importantly, the outcomes of those transitions.  (Virginia, which would be the 19^th State-Based Marketplace, launched on November 1, 2023. Virginia is not included in the total number of SBMs since it was not operating as an SBM from the beginning of the unwinding.)

The Centers for Medicare & Medicaid Services (CMS) continues to release required state data reporting metrics. In December, CMS released a new batch of data which included information on Marketplace enrollment transition data as of September 2023. CMS also continued to point to the increase in Marketplace enrollment (an increase of 1.5 million people between March and September 2023) as a signal of strong transition rates. CMS continues to report slightly different data for states that use HealthCare.gov compared to SBMs. And among SBMs, for states with an integrated system versus those who transfer accounts between Medicaid and the Marketplace. Broadly, these data include:

• Consumers who were transferred to or applied for Marketplace coverage.
• Consumers who were eligible for a QHP or Basic Health Plan (BHP) coverage (disaggregated by those eligible for financial assistance).
• Consumers with a QHP selection or BHP enrollment.

In all cases, CMS provides both counts and percentages. Among SBM states without an integrated system, CMS provides two percentage calculations – one where the denominator is applications and one where the denominator is account transfers. This distinction is important, because using the much larger account transfers number as a denominator makes the successful rate of transitions to QHP coverage seem much smaller. While the presentation of the CMS data is clear and the availability of counts and percentages is useful, it could leave room for misinterpreting the denominator.

Data reporting and interpretation have been complicated by several factors causing delays in renewal processing and changes to states’ timelines. First, the announcement from CMS on August 30, 2023 that 29 states and the District of Columbia had been making ex parte renewal determinations on a household, rather than an individual level, as regulations require. This included 16 of the 18 SBMs (California and Rhode Island were in compliance). This caused some states to pause procedural terminations, reinstate coverage, and/or implement temporary extensions for renewal. Second, CMS offered states the option of delaying procedural disenrollments while they conduct targeted renewal outreach. To date, 15 states have opted to take advantage of this flexibility. 

Given the ongoing data concerns and cautions regarding state comparisons, differences in how states are managing changes to ex parte renewals and potential confusion regarding the use of different denominators, it is more important than ever for SBMs to release their own data.

SHADAC will continue to update this expert perspective as more states publish their unwinding data
 

State-Based Marketplace Reporting Marketplace Transition Outcome Data
 

Note: In some cases, SBMs publish Marketplace transition outcome data in administrative documents (e.g., board meeting minutes and legislative reports). Because these data are more difficult to access, they are not represented in the map above.  

Variation in State Reporting

To date, 12 of the 18 SBMs that use their own eligibility platform are reporting outcomes for individuals who exited Medicaid and were transitioned to the Marketplace. While most of these states continue to update their data frequently, three states haven’t released updated data since October 2023. In summary:

• Seven states are reporting whether individuals were eligible for a QHP.
• 11 states are reporting whether individuals selected a plan.
• Five states are reporting enrollment and/or eligibility broken down by whether the individual received financial assistance (e.g., advance premium tax credit or cost-sharing reduction payments).
• Three states are reporting on the demographics of people transitioning from Medicaid to Marketplace coverage.
• One state, Idaho, reports having completed its redeterminations.

Select Data Highlights
In addition to general information on transition outcomes, most of the states reporting outcome measures are providing additional information of interest, though this detail differs by state. Select data highlights are provided on the SHVS Expert Perspective .