Medicaid disenrollments resumed several months ago (in April, May, June, or July, depending on the state), and the process is proceeding largely as expected, with millions currently disenrolled. However, it has also encountered some unforeseen challenges.
Here is an overview of disenrollments so far, including who has lost Medicaid coverage and how some disenrolled individuals are seeking alternative insurance options.
How Many People Have Been Disenrolled from Medicaid?
As of October 19, more than 9 million people had been disenrolled from Medicaid due to states resuming disenrollments after the pandemic-era federal continuous coverage requirement ended in the spring of 2024.
Eligibility redeterminations—also known as renewals—must be conducted for all Medicaid enrollees during a year-long “unwinding” period. These disenrollments were not unexpected; HHS had projected that around 15 million people would be disenrolled from Medicaid during the unwinding of the pandemic-era continuous coverage rules.
States had the option to prioritize eligibility redeterminations for enrollees they believed were most likely to no longer be eligible, so it is not surprising that there was a relatively high rate of disenrollments in some states in the early months of the unwinding process. For example, by September 2024, Idaho had already completed eligibility redeterminations for everyone whose eligibility had been pending during the pandemic and is now back to its normal annual eligibility redeterminations.
Most Disenrollments Due to Procedural Reasons
What may be surprising is that nearly three-quarters of the disenrollments have been for procedural reasons, meaning that a state was unable to determine whether a person who had Medicaid coverage was still eligible. This issue can arise when a Medicaid office does not have a beneficiary’s current contact information.
In some cases, a beneficiary received a renewal package but has not submitted the necessary information for the state to process the renewal. This could be because the individual knows they are no longer eligible and may have already enrolled in other coverage (such as a plan offered by a new employer). However, in other cases, the beneficiary may not understand what is required to complete the renewal or may have simply fallen behind on paperwork.
CMS Pauses Procedural Enrollments in 29 States and D.C.
In late August 2024, the Centers for Medicare and Medicaid Services (CMS) addressed the issue that many states had problematic renewal processes involving families where some members were eligible for ex parte (automatic) renewals and others were not. In many states, renewal documents were sent to the household, and if they were not completed, the entire family was being disenrolled—including household members (often children) who were eligible for ex parte renewal.
Twenty-nine states and the District of Columbia have had to pause procedural disenrollments until they can confirm that eligible individuals are not being disenrolled due to eligibility redeterminations being conducted at the family (rather than individual) level. CMS also directed states to reinstate coverage for nearly 500,000 individuals—many of whom are children—whose coverage had been improperly terminated due to this issue.
CMS had previously instructed some states to pause procedural disenrollments while addressing issues with their eligibility redetermination processes. As of June 2024, some or all procedural disenrollments had been paused in D.C. and 16 states.
A pause on procedural disenrollments does not prevent a state from continuing to process renewals and disenroll individuals who no longer meet the eligibility criteria. It simply prevents states from disenrolling individuals when they lack sufficient information to determine continued eligibility.
States can also adjust their approach to Medicaid redeterminations based on specific state conditions. For example, Hawaii opted to pause all Medicaid disenrollments through the end of 2025 due to the wildfires in Maui and will wait until June 2025 to resume eligibility redeterminations for West Maui residents.
How Many People Have Transitioned from Medicaid to Marketplace Coverage?
Individuals who are no longer eligible for Medicaid can switch to other coverage, typically from an employer, Medicare, or the Marketplace. Eligibility for each type of coverage depends on the individual’s specific circumstances.
In September 2024, CMS released data on Marketplace enrollments among individuals who had recently been enrolled in Medicaid. As of June 2024:
- More than 291,000 former Medicaid enrollees had chosen Marketplace-qualified health plans (QHPs) through HealthCare.gov.
- More than 63,000 individuals had selected QHPs through state-run exchanges.
- Additionally, nearly 56,000 people had transitioned to Basic Health Program (BHP) coverage in New York and Minnesota.
Based on CMS’ latest reports, more than 410,000 former Medicaid enrollees had transitioned to Marketplace coverage—either QHP or BHP—by June 2024.
In the state-run exchanges, enrollment included nearly 7,600 individuals for whom a QHP had been automatically selected. Only four states (California, Maryland, Massachusetts, and Rhode Island) have implemented auto-enrollment procedures for at least some individuals whose Medicaid coverage is terminated during the unwinding process. In the rest of the country, a person’s data may be transferred to the Marketplace, but they must actively choose a plan to enroll in a QHP.
Subsidies for Medicaid Beneficiaries Transitioning to Marketplace Coverage
Last year, CMS estimated that 2.7 million individuals losing Medicaid during the unwinding period would be eligible for advance premium tax credits (APTC) to offset the cost of Marketplace coverage. As of June 2024, a total of about 583,000 former Medicaid enrollees had been deemed eligible for APTC (337,230 in states using HealthCare.gov and 245,879 in states with their own exchanges).
APTC eligibility depends on income and whether the individual has an offer of affordable employer-sponsored coverage. Individuals who lose Medicaid but are eligible for an employer’s plan are typically not eligible for financial assistance in the Marketplace.
Special Enrollment in the Marketplace for Those Disenrolled from Medicaid
HealthCare.gov has a special enrollment period, running through July 2025, for individuals who lose Medicaid during the unwinding process. This means that someone who lost Medicaid early in the unwinding process still has an extended window to enroll in a Marketplace plan if they choose.
States with their own exchanges can offer extended special enrollment periods for individuals losing Medicaid or follow standard special enrollment period rules, which typically allow 60 days to choose a new plan after losing Medicaid.
What Should Current Enrollees Expect as Medicaid Redetermination Continues?
While the number of disenrollments exceeds 9 million, the redetermination process is still ongoing. Current enrollees should watch for communications from their state’s Medicaid office, especially if their coverage has not been renewed recently.
In most states, the eligibility redetermination process begins two or three months before an enrollee’s renewal date. Federal regulations require states to give most Medicaid enrollees at least 30 days to return their renewal packages, but states often allow 45 days or more. (For Medicaid enrollees who are 65 or older, or who qualify due to disability or blindness, the state must provide “a reasonable amount of time.”)
If the state can renew an individual’s coverage automatically, the beneficiary will receive a notice confirming renewal. Otherwise, the state will inform them of the required information for renewal and provide a deadline of at least 30 days.
If an individual does not submit the required documents by the deadline, coverage may be terminated. However, if a beneficiary submits renewal information within 90 days of coverage termination, states must determine eligibility without requiring a new application and reinstate coverage if the individual qualifies.