New Analysis of Historic Medicaid Churn Rates Highlights Implications for Ending Continuing Enrollment Requirement for Pandemic Funding


For more than a year and a half, the continued enrollment requirement tied to improved Medicaid funding during the COVID-19 pandemic has virtually halted “attrition,” the temporary loss of coverage in which people fall. deregister from Medicaid and then re-register within a short period of time.

These opt-outs are expected to resume once the requirement is completed and states will begin processing new Medicaid eligibility determinations. People can lose their coverage if they are no longer eligible or if they encounter obstacles during the reassessment process, such as providing the required documents.

A new KFF analysis who looked at churn rates before the pandemic found that about 10 percent of full benefit Medicaid registrants experienced a coverage gap of less than a year. The rates, which varied by state, were higher for children and adults than for seniors and people with disabilities. Federal rules and state policy decisions on resuming unsubscribes will influence unsubscribe rates after the continuous registration requirement ends.

All of this is an important context for the Build Back Better Act (BBBA) debate in Congress. The House version of the bill includes provisions to phase out the continuous registration requirement for Medicaid, with rules that would limit how aggressively states could unenroll people. For example, states could only deregister individuals who were enrolled for at least 12 consecutive months and must limit eligibility reviews to one-twelfth of all enrollees per month until September 2022. States could not unenroll them. people based on returned mail unless there are two or more unsuccessful attempts to contact the individual by two or more different methods (eg, mail and text messages).

The BBBA would also require states to extend 12-month continuous coverage for children in Medicaid and CHIP (currently an option for states) and would require 12-month continuous coverage for postpartum individuals, a change from the current 60-day postpartum coverage requirement. and a temporary option available to states through the American Rescue Plan Act (ARPA).

For the full analysis of historical Medicaid enrollment churn rates and a summary of BBBA provisions that would limit a reversion to churn, visit


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