No child should go a single day without access to health care coverage. Even short gaps in coverage interrupt children’s access to care, which, especially for young children, can impact their health and development into adulthood. Starting tomorrow, April 1st, families around the country will begin to see a process unfold that could result in nearly 7 million children losing their health coverage. No, that is not an April Fools’ joke. 

During the COVID-19 pandemic, Congress provided additional Medicaid funding to states based on meeting several requirements, including a continuous coverage requirement that prohibited states from terminating a child or parent’s Medicaid coverage during the COVID-19 public health emergency (PHE). With the Consolidated Appropriations Act, 2023, Congress delinked the continuous coverage requirements from the end of the PHE and set April 1st as the date when states can begin what has been called “unwinding.” “Unwinding” means that states can disenroll children and families from Medicaid who no longer qualify and resume the state’s normal course of annual Medicaid eligibility reviews. States will have the next year to conduct the unwinding process and make redeterminations for the 85 million Americans enrolled in Medicaid, including over 34.7 million children

While unwinding might seem like a simple return to the normal operating procedure for state Medicaid agencies, if they do not proceed with caution people will unnecessarily lose coverage. In fact, children are at the greatest risk of unnecessary coverage loss. According to a report by the Department of Health and Human Services (HHS), nearly 74% of children who are projected to lose coverage will still be eligible for Medicaid

You might be asking, “How can so many children be disenrolled despite remaining eligible?” There is no single answer but some reasons include: 

  • Barriers in the renewal process: Certain individuals will be at higher risk of experiencing a gap in coverage or losing their Medicaid completely due to barriers in the renewal process, including: 
    • Children of families who moved during the pandemic not receiving important information about their Medicaid renewal or other notices 
    • Notices not being in clear, understandable language that articulates the steps families must take to renew their child’s coverage 
    • Families with limited-English proficiency (LEP) not receiving paperwork in their preferred language 
    • People with disabilities encountering challenges due to not being able to access information in needed formats. 
  • Crushing workload: The unwinding process will mark the first time since March 2020 that many state Medicaid workers are processing redeterminations — and they have millions to process. Even the most well-intentioned workers are likely to make mistakes due to the sheer workload. Additionally, while some states have made efforts to ramp up their staffing for redeterminations and call centers, the number of redeterminations will test capacity levels. 
  • Short processing windows: States can take the next year to get through their Medicaid redeterminations. However, some states plan to unwind with shorter time frames. For example, Arkansas has said it wants to do the entire process in six months. Forcing short time frames on families to return paperwork and on state workers making the redeterminations will increase the likelihood of mistakes that can cause kids to slip through the cracks. 

To avert some of these unnecessary coverage losses, Congress established safeguards in the budget bill it passed at the end of 2022. States must: 

  • Comply with federal law on redeterminations 
  • Update enrollee contact information through national databases 
  • Make good faith efforts to contact enrollees before disenrolling them based on returned mail 
  • Not raise premiums or make changes to their Medicaid eligibility standards, methodologies, or procedures
  • Submit monthly reports with information about redetermination activities 

In line with these requirements, states must, to the greatest extent possible, use available data to renew the eligibility of children and families without requiring additional paperwork unless absolutely necessary. Where paperwork is necessary, states must send information and notices that are clear and available in the preferred language of families; follow up with families who need to submit documents through multiple methods of communication; and make good-faith efforts to contact families who may have moved during the pandemic. 

Beyond state action, HHS must ensure the appropriate and timely oversight of state unwinding activities. For states that are struggling with unwinding, the Secretary must use his authority to ensure those states swiftly implement a corrective action plan and, in the most egregious cases, are penalized (as allowed by law) or have their eligibility redetermination activities suspended. 

Again, kids losing health care coverage is no joke. We are counting on the states to mitigate unnecessary coverage losses for children and the federal government to hold them accountable for doing so.