Nearly 85 million people enrolled in Medicaid will have their eligibility redetermined at the end of the public health emergency, triggering a high risk of coverage loss of eligible individuals. In light of what is being referred to as the “unwinding,” CMS officials released a template that states must use to detail their plans to process renewals for millions of Medicaid recipients who have remained on their state’s programs during the pandemic.

A federal mandate instituted toward the beginning of the public health crisis dictates that anyone enrolled in Medicaid cannot lose coverage during the pandemic. Prior to the public health crisis, states regularly evaluated whether residents still qualified for the safety-net program. The pandemic has suspended those routines for the past two years, leading to record-high enrollments across the country. HHS extends the public health emergency in 90-day increments, and it is currently set to end April 16.

According to new CMS guidance, states will be required to share with the federal government how many renewals they plan to begin processing during each month of the year-long “unwinding period,” which methods they will be taking and how they plan to limit coverage losses. States will be required to submit the form to CMS by the 45th day before the end of the month in which the public health emergency ends.

Will states be ready to submit this data? A new Kaiser Family Foundation poll found that nearly every state is capable of tracking call-center statistics and a majority can report the share of disenrollments that were determined ineligible (as opposed to disenrollments that occurred due to procedural reasons). Having timely and reliable data from states is needed to monitor the unwinding process and assess whether additional steps should be taken to avoid coverage losses among those who remain eligible. However, the majority of states report that an increase in income will be the primary reason for the disenrollment, although several states also anticipate incomplete renewals or missing documentation will be a primary reason for disenrollment. In the 20 states currently able to report it, it is estimated that approximately 13 percent of Medicaid enrollees will lose coverage when the public health emergency ends.

Several states have already announced plans to tackle the unwinding. The Oregon state legislature created a task force earlier this month that has been charged with looking at ways the state could create a “bridge plan.” This plan would cover basic health and dental coverage for people who get disenrolled from the state’s Medicaid program, the Oregon Health Plan. Currently, the Oregon Health Plan is available for individuals earning up to 138 percent of the Federal Poverty Level as well as pregnant women who make up to 185 percent of the FPL. The bridge plan would be for individuals making between 138 percent and 200 percent of the FPL.

The Ohio Department of Medicaid says that no one will be disenrolled without an eligibility redetermination or two failed attempts to obtain verification from the enrollee. To avoid falling into the two-failed-attempts category, the agency has urged Ohioans to double-check that their contact information is current and complete – especially their current mailing address.

In California, the state’s Medi-Cal director announced that the state would have to begin the process of redetermining who is eligible in May if the emergency order ends in April. Since enrollees need a 60-day notice, individuals who are due to update their eligibility information in July would need renewal packages by May.