States are continuing to disenroll Medicaid recipients at a staggering rate, with a large percentage of those losing their coverage still eligible for the program. While the Medicaid redetermination process is federally mandated, there is little the Biden Administration can do to prevent these “procedural disenrollments” beyond providing guidance to state Medicaid agencies. Procedural disenrollments refer to cases where beneficiaries still qualify for Medicaid based on their income or disability status, but have lost coverage due to missing paperwork, inability to verify income, or other administrative errors. As of June 29, at least 1,536,000 Medicaid enrollees have been disenrolled based on the most current data from 27 states and the District of Columbia. Experts believe as many as 17 million could lose coverage by the end of the year.

Earlier this month, the U.S. Department of Health and Human Services (HHS) offered states new flexibilities in an effort to slow down disenrollments. These new flexibilities included allowing managed care plans to assist people with Medicaid with completing their renewal forms, allowing states to delay an administrative termination for one month while the state conducts additional targeted outreach, and allowing pharmacies and community-based organizations to facilitate reinstatement of coverage for those who were recently disenrolled for procedural reasons based on presumptive eligibility criteria. Congressional Democrats have recently called on the Biden Administration to take a stronger role in the Medicaid redetermination process, urging the Centers for Medicare & Medicaid Services (CMS) to threaten to defund state Medicaid programs if they don’t take action to prevent procedural disenrollments. While CMS has the power to cut funding to individual state Medicaid programs, this move is rarely used.