States Should Resist CMS Schemes That Keep Medicaid Enrollment High

Background

In 2000, there were 34.5 million Americans enrolled in Medicaid.¹ By 2023, slightly more than two decades later, enrollment reached an all-time high of 100 million.² From July 2022 to June 2023, total spending on Medicaid was nearly $852 billion.³ In response to the COVID-19 pandemic, Congress prohibited states from removing individuals from Medicaid rolls, providing for continuous eligibility without verification for multiple years.⁴ The ensuing surge in enrollment is gradually being corrected by states. However, there were still more than 92.4 million individuals enrolled in the program as of September 2023—24 percent higher than the pre-pandemic enrollment of 74 million.^5-6  

As Medicaid spending and enrollment remain high, improper payments and ineligible enrollees remaining on Medicaid cost millions, contributing to budget shortfalls.⁷ In the 2020 review of Medicaid payments, the last review period that does not include pandemic-era flexibilities, more than one in five dollars spent was improper.⁸ The vast majority of improper payments are due to eligibility errors alone.^9-11  

Among federal programs, Medicaid accounts for the largest share of improper payments, comprising 32 percent of all federal improper payments.¹² State audits have found Medicaid making payments to people enrolled in multiple states at the same time, those who had not accurately reported income or their household composition, and those who had been dead for years.¹³ 

During the public health emergency, states did not conduct eligibility reviews that could reveal errors in payments, and as a result, the reported payment error rate dropped.¹⁴ Because states did not verify eligibility criteria during this time period, and there was an unprecedented surge in enrollment, it is likely that the true payment error rate from these years is much higher.¹⁵ Medicaid is on track to surpass $1 trillion in improper payments over the next decade.¹⁶ 

While during the public health emergency states were handcuffed from removing ineligible enrollees from Medicaid, states are now in the process of verifying eligibility and cleaning up their Medicaid rolls.¹⁷ Some states, such as Florida and Texas, prioritized disenrolling ineligible enrollees and did so more quickly than other states.^18-19 However, CMS has extended the use of waivers that allow states to avoid normal eligibility rules through June 2025 and has taken other steps to ensure that enrollment and spending will remain elevated.²⁰ Through this new guidance and other means, CMS is working to keep enrollment as high as possible.²¹    

CMS is working to boost Medicaid enrollment and keep it high

Despite federal law outlining who is eligible for Medicaid, CMS is trying to maximize enrollment and minimize state tools that ensure welfare is preserved for the truly needy. 

1. New CMS rule limits states’ ability to check eligibility

In April 2024, the Biden administration finalized a rule that removes state options for determining Medicaid eligibility.²² For example, the rule prohibits states from checking eligibility more than once per year.²³ The stated goal of this rule is to increase enrollment and retention in Medicaid and reduce the number of individuals who are disenrolled.²⁴ CMS estimates that the new rule will add an additional 1.3 million enrollees to Medicaid and cost nearly $59 billion in the first five years of implementation.²⁵ CMS consistently underestimates actual costs and enrollment in Medicaid, and the true cost would likely be much higher.²⁶

Factors that impact eligibility, such as income, residency, or household composition, can change over the course of a year. Before the pandemic, the average Medicaid enrollee was only eligible for an average of 10 months, and able-bodied adults were only eligible for an average of 8.6 months out of a year.²⁷ During the course of one year, 53 percent of low-income households experience significant fluctuations in income.²⁸ Verifying eligibility more than once per year is a commonsense approach to ensuring that resources are preserved for those who truly need them.²⁹    

In addition, the rule prohibits in-person, phone, or video interviews and follow-up questions to verify eligibility for some recipients and eliminates the requirement that applicants seek other sources of support such as disability benefits or a pension.³⁰ It also requires states to establish a lengthy reconsideration period during which applicants can submit more information, keeping cases open for longer and resulting in higher enrollment.³¹ 

2. Multi-year continuous eligibility waivers

Section 1115 waivers allow states to obtain permission from CMS to demonstrate new approaches to running Medicaid programs and stray from the typical program administration rules set forth by CMS.³² During the Trump administration, states were approved for waivers that implemented work requirements and enhanced program integrity.³³ President Biden’s CMS rescinded all existing waivers for work requirements and is encouraging states to implement waivers that weaken program integrity and expand eligibility and benefits.³⁴    

One type of waiver allows continuous Medicaid eligibility for multiple years for certain populations.³⁵ As of January 2024, CMS has implemented 12-month continuous eligibility for children in all states, meaning that even if a family’s circumstances change and they are no longer eligible for Medicaid, children under the age of 19 remain on Medicaid until the end of a 12-month enrollment period.³⁶ Additionally, at least 11 states are pursuing or already have implemented waivers related to multi-year continuous eligibility for certain groups.^37-39

Oregon provides all Medicaid enrollees over the age of six with 24 months of continuous eligibility, and those under the age of six with up to six years of continuous eligibility.⁴⁰ This means that in Oregon, a working adult can remain on the Medicaid rolls for two years, no matter how high their income rises.⁴¹ The only way to remove someone from Medicaid during this two-year period is if they self-report a move out of the state, or request to be removed.⁴²    

New York is applying for an amendment to their existing waiver to provide continuous eligibility for children up to the age of six.⁴³ Already, families with children can earn up to four times the federal poverty level before losing eligibility for Medicaid, which is a six-figure income.⁴⁴ This provision is expected to cost more than $44 million.⁴⁵ At the same time, New York is making cuts to other areas of Medicaid, such as nursing home reimbursements, and proposing tax increases on providers due to budget shortfalls for Medicaid.⁴⁶    

The Biden administration’s fiscal year 2025 budget request goes beyond encouraging these waivers and proposes a new state option for states to provide six-year continuous eligibility for young children, which would cost $4.2 billion.⁴⁷ It also proposes an additional three years of continuous eligibility for all individuals under the age of 19, at a cost of $5.4 billion over 10 years.⁴⁸ Under the Biden administration’s proposal, a state could adopt both options to provide nearly a decade of coverage to a family without regard for their income or other eligibility factors.⁴⁹ Subsidizing parents who earn well above the eligibility limits for Medicaid is not in line with the goal of the Medicaid program.⁵⁰

3. Accepting self-attestation and post-enrollment income verification

CMS has encouraged states to boost enrollment by allowing self-attestation without documentation for some eligibility criteria, and post-enrollment verification of other factors.⁵¹   

The District of Columbia and the State of Illinois each allow self-attestation for factors such as eligibility for other health coverage and residency.⁵² It is no surprise that Medicaid enrollment in Illinois has outpaced projections. When Medicaid expansion was first authorized in Illinois, it was projected to add 342,000 able-bodied adults.⁵³ By 2023, there were more than 900,000 able-bodied adults on the program.⁵⁴ The improper payment rate in Illinois has surged alongside enrollment, sitting at 37 percent.⁵⁵  

Income is required to be verified with documentation, but seven states have chosen to verify income after an applicant is already enrolled.⁵⁶ In these states, individuals who report having no income or low income may be covered while their income is being verified, which opens the door to fraud and abuse.  

4. Political targeting of states that are disenrolling ineligible Medicaid recipients

In April 2023, states were allowed to begin performing Medicaid redeterminations for the first time in more than three years.⁵⁷ States approached this process differently. Some states slow-walked disenrollment, while others sought to efficiently complete the process by prioritizing redeterminations for those believed to be ineligible.⁵⁸   

Rather than applauding the efforts of states to ensure that only those eligible remain on the rolls, the Biden administration has engaged in political targeting of certain states. Nine states, all with Republican governors, received warning letters from CMS about the redetermination process.⁵⁹ CMS focused on what they call “procedural disenrollment,” which means that enrollees were removed because their applications were missing information or were not submitted.⁶⁰ Despite what CMS implies, these “procedural” removals from Medicaid are not necessarily cases of eligible enrollees being removed. While some individuals may regain Medicaid eligibility, others are actually ineligible and did not return the application for that reason.⁶¹   

States such as Colorado and Massachusetts have also disenrolled millions for so-called “procedural reasons,” yet were not targeted for a public rebuke.⁶² States that have slow-walked the process have not been criticized by CMS for failing to remove ineligible Medicaid recipients in a timely manner. It is responsible for states to discontinue Medicaid coverage for individuals who are not demonstrably eligible under the law, and doing so should not be penalized by the federal government.

5. Delaying a return to normal eligibility rules and processes after the pandemic

In addition to criticizing certain states for efficiently processing redeterminations during the post-pandemic unwinding period, CMS has acted to delay a return to normal eligibility rules and processes. Originally, states were supposed to complete the redetermination process for all Medicaid enrollees by June 2024. CMS extended this deadline to December 2024, and then again to June 2025—more than five years after the start of the public health emergency.⁶³    

As states began to conduct redeterminations, CMS issued nearly 400 temporary waivers to allow states to use processes that are not part of their state plan.⁶⁴

In their latest extension, CMS extended the approval of the temporary waivers beyond the initial approval period without requiring another application.⁶⁵ Some of these waivers include allowing managed care organizations to complete and submit applications on behalf of enrollees and eliminating requirements that individuals apply for other types of benefits.⁶⁶   

CMS is also encouraging states to use the same waiver authority to reenroll the same beneficiary more than once.⁶⁷ For example, a state is permitted to renew Medicaid for an individual whose income was at or below 100 percent of the federal poverty level in March 2019 multiple times as long as searches of electronic data sources don’t indicate higher income.⁶⁸ For these individuals, income will not be formally verified for up to six years.

States that paused disenrollments due to applications or requests for information not being returned in a timely manner are encouraged by CMS to continue delaying redeterminations until June 2025.⁶⁹ While these redeterminations are delayed, ineligible individuals will continue to receive Medicaid. 

States should resist CMS’s strategies and preserve Medicaid for the truly needy

While some important changes to Medicaid cannot be accomplished without federal leadership, states should put safeguards in place to enhance program integrity despite the Biden administration’s best efforts. States can require documentation of eligibility factors such as access to other health insurance coverage and residency and decline to allow post-enrollment verification for income.  

States should also cross-check data between welfare programs to identify ineligible enrollees and fraud.⁷⁰ States have records of incarceration, deaths, tax records, and lottery winnings.⁷¹  

These data sources should be used to verify eligibility.⁷² States should impose a temporary lock-out for those found to be committing fraud.⁷³ States such as Iowa, Florida, and Texas have implemented stronger program integrity measures, and have lower payment error rates than states that have not.⁷⁴ 

The Bottom Line: While CMS pursues strategies to surge Medicaid enrollment, states and Congress should implement safeguards to Medicaid to ensure that resources are preserved for the truly needy.

The pandemic-era strategy to maximize Medicaid enrollment at all costs proved to be catastrophic for state budgets. While ineligible adults remained on the rolls, states made cuts to nursing homes and other areas of Medicaid, which help the truly needy. Despite no longer having a public health emergency to justify handcuffing states, the Biden administration continues to perpetrate schemes to maximize enrollment at the expense of program integrity and at great cost to taxpayers. States and Congress should implement safeguards to ensure that Medicaid dollars are only spent on those who are eligible to receive assistance and are truly in need. 

REFERENCES

1. Jonathan Bain, “The X factor: How skyrocketing Medicaid enrollment is driving down the labor force,” Foundation for Government Accountability (2022), https://thefga.org/research/x-factor-medicaid-enrollment-driving-down.labor-force.
2. Jonathan Bain, “Busted budgets and skyrocketing enrollment: Why states should reject the false promises of Medicaid expansion,” Foundation for Government Accountability (2023), https://thefga.org/research/states-should-reject-false-promises-of-medicaid-expansion.
3. Centers for Medicare & Medicaid Services, “Expenditure reports from MBES/CBES,” U.S. Department of Health and Human Services (2024), https://www.medicaid.gov/medicaid/financial-management/state-expenditure-reporting-for-medicaid-chip/expenditure-reports-mbescbes/index.html.
4. Jonathan Ingram and Sam Adolphsen, “Stopping the Medicaid madness: How Congress and states can start salvaging some program integrity,” Foundation for Government Accountability (2022), https://thefga.org/research/stopping-the-medicaid-madness-how-congress-and-states-can-start-salvaging-some-program-integrity.
5. Centers for Medicare & Medicaid Services, “Medicaid enrollment,” U.S. Department of Health and Human Services (2024), https://data.medicaid.gov/dataset/6c114b2c-cb83-559b-832f-4d8b06d6c1b9/data?conditions%5B0%5D%5Bproperty%5D=enrollment_year&conditions%5B0%5D%5Bvalue%5D=2023&conditions%5B0%5D%5Boperator%5D=%3D&conditions%5B1%5D%5Bproperty%5D=enrollment_month&conditions%.
6. Jonathan Bain and Sam Adolphsen, “Maximize enrollment, weaken program integrity: How the Biden administration’s proposed Medicaid rule would decimate an already broken program,” Foundation for Government Accountability (2022), https://thefga.org/research/maximize-enrollment-weaken-program-integrity.
7. Hayden Dublois and Jonathan Ingram, “Ineligible Medicaid enrollees are costing taxpayers billions,” Foundation for Government Accountability (2022), https://thefga.org/paper/ineligible-medicaid-enrollees-costing-taxpayers-billions.
8. Centers for Medicare & Medicaid Services, “2020 Medicaid and CHIP supplemental improper payment data,” U.S. Department of Health and Human Services (2020), https://www.cms.gov/files/document/2020-medicaid-chip-supplemental-improper-payment-data.pdf.
9. Ibid.
10. Centers for Medicare & Medicaid Services, “2021 Medicaid and CHIP supplemental improper payment data,” U.S. Department of Health and Human Services (2021), https://www.cms.gov/files/document/2021-medicaid-chip-supplemental-improper-payment-data.pdf-1
11. .Centers for Medicare & Medicaid Services, “2022 Medicaid and CHIP supplemental improper payment data,” U.S. Department of Health and Human Services (2022), https://www.cms.gov/files/document/2022-medicaid-chip-supplemental-improper-payment-data.pdf-0.
12. Government Accountability Office, “Improper payments: Fiscal year 2022 estimates and opportunities for improvement,” (2023), https://www.gao.gov/assets/gao-23-106285.pdf.
13. Jonathan Bain and Sam Adolphsen, “Maximize enrollment, weaken program integrity: How the Biden administration’s proposed Medicaid rule would decimate an already broken program,” Foundation for Government Accountability (2022), https://thefga.org/research/maximize-enrollment-weaken-program-integrity.
14. Government Accountability Office, “Medicare and Medicaid: Additional actions needed to enhance program integrity and save billions,” Government Accountability Office (2024), https://www.gao.gov/products/gao-24-107487
15. .Ibid.
16. Jonathan Bain, “Medicaid mismanagement: How states can restore integrity to the program while saving taxpayers billions,” Foundation for Government Accountability (2023), https://thefga.org/research/medicaid-mismanagement-states-can-restore-integrity.
17. Centers for Medicare & Medicaid Services, “Unwinding and returning to regular operations after COVID-19,” U.S. Department of Health and Human Services (2023), https://www.medicaid.gov/resources-for-states/coronavirus-disease-2019-covid-19/unwinding-and-returning-regular-operations-after-covid-19/index.html.
18. Florida Department of Children and Families, “Medicaid redetermination,” State of Florida (2023), https://www.myflfamilies.com/medicaid.
19. Texas Department of Health and Human Services, “HHSC resumes Medicaid eligibility redeterminations as continuous coverage requirement ends,” State of Texas (2023), https://www.hhs.texas.gov/news/2023/04/hhsc-resumes-medicaid-eligibility-redeterminations-continuous-coverage-requirement-ends.
20. Centers for Medicare & Medicaid Services, “CMCS informational bulletin,” Centers for Medicare & Medicaid Services (2024), https://www.medicaid.gov/federal-policy-guidance/downloads/cib050924-e14.pdf.
21. Chelsea Cirruzzo, “Biden administration pleads with states after millions of kids lose Medicaid coverage,” Politico (2023), https://www.politico.com/news/2023/12/18/biden-administration-pleads-with-states-after-millions-of-kids-lose-medicaid-coverage-00132282.C
22. enters for Medicare & Medicaid Services, “Medicaid program; streamlining the Medicaid, Children’s Health Insurance Program, and Basic Health Program application, eligibility determination, enrollment, and renewal processes,” Federal Register 89(64): 22780-878 (2024), https://www.govinfo.gov/content/pkg/FR-2024-04-02/pdf/2024-06566.pdf.
23. Ibid.
24. Centers for Medicare & Medicaid Services, “Biden-Harris administration builds on the success of the Affordable Care Act by streamlining enrollment in Medicaid and CHIP coverage,” U.S. Department of Health and Human Services (2024), https://www.cms.gov/newsroom/press-releases/biden-harris-administration-builds-success-affordable-care-act-streamlining-enrollment-medicaid-and.
25. Centers for Medicare & Medicaid Services, “Medicaid program; streamlining the Medicaid, Children’s Health Insurance Program, and Basic Health Program application, eligibility determination, enrollment, and renewal processes,” Federal Register 89(64): 22780-878 (2024), https://www.govinfo.gov/content/pkg/FR-2024-04-02/pdf/2024-06566.pdf.
26. Jonathan Bain and Sam Adolphsen, “Maximize enrollment, weaken program integrity: How the Biden administration’s proposed Medicaid rule would decimate an already broken program,” Foundation for Government Accountability (2022), https://thefga.org/research/maximize-enrollment-weaken-program-integrity.
27. Sarah Sugar et al., “Medicaid churning and continuity of care: Evidence and policy considerations before and after the COVID-19 pandemic,” U.S. Department of Health and Human Services (2021), https://aspe.hhs.gov/sites/default/files/private/pdf/265366/medicaid-churning-ib.pdf.
28. Ibid.
29. Jonathan Bain and Sam Adolphsen, “Maximize enrollment, weaken program integrity: How the Biden administration’s proposed Medicaid rule would decimate an already broken program,” Foundation for Government Accountability (2022), https://thefga.org/research/maximize-enrollment-weaken-program-integrity.
30. Ibid.
31. Centers for Medicare & Medicaid Services, “Medicaid program; streamlining the Medicaid, Children’s Health Insurance Program, and Basic Health Program application, eligibility determination, enrollment, and renewal processes,” Federal Register 89(64): 22780-878 (2024), https://www.govinfo.gov/content/pkg/FR-2024-04-02/pdf/2024-06566.pdf.
32. Centers for Medicare & Medicaid Services, “About section 1115 demonstrations,” U.S. Department of Health and Human Services (2024), https://www.medicaid.gov/medicaid/section-1115-demonstrations/about-section-1115-demonstrations/index.html.
33. Centers for Medicare & Medicaid Services, “CMS announces new policy guidance for states to test community engagement for able-bodied adults,” U.S. Department of Health and Human Services (2018), https://www.cms.gov/newsroom/press-releases/cms-announces-new-policy-guidance-states-test-community-engagement-able-bodied-adults.
34. Allexa Gardner and Ryan Lee, “Biden administration takes further action to end barriers to Medicaid coverage,” Georgetown University McCourt School of Public Policy Center for Children and Families (2021), https://ccf.georgetown.edu/2021/08/18/biden-administration-takes-further-action-to-end-barriers-to-medicaid-coverage.
35. Centers for Medicare & Medicaid Services, “State waivers list,” U.S. Department of Health and Human Services (2024), https://www.medicaid.gov/medicaid/section-1115-demo/demonstration-and-waiver-list/index.html.
36. Centers for Medicare & Medicaid Services, “Section 5112 requirement for all states to provide continuous eligibility to children in medicaid and CHIP under the Consolidated Appropriations Act, 2023,” Centers for Medicare & Medicaid Services (2023), https://www.medicaid.gov/sites/default/files/2023-09/sho23004.pdf.
37. Centers for Medicare & Medicaid Services, “State waivers list,” U.S. Department of Health and Human Services (2024), https://www.medicaid.gov/medicaid/section-1115-demo/demonstration-and-waiver-list/index.html.
38. California Department of Health Care Services, “CalAIM 1115 demonstration & 1915(b) waiver,” State of California (2024), https://www.dhcs.ca.gov/provgovpart/Pages/CalAIM-1115-and-1915b-Waiver-Renewals.aspx.
39. Colorado Department of Health Care Policy & Financing, “Colorado Medicaid coverage for justice-involved population re-entry, severe mental illness, and continuous eligibility,” State of Colorado (2024), https://hcpf.colorado.gov/sites/hcpf/files/Amendment_1115_SUD_Waiver_2024.1.24.pdf.
40. Oregon Health Authority, “2022-2027 Medicaid 1115 demonstration wavier,” State of Oregon (2022), https://www.oregon.gov/oha/hsd/medicaid-policy/pages/waiver-renewal.aspx?utm_source=OHA&utm_medium=egov_redirect&utm_campaign=https%3A%2F%2Fwww.oregon.gov%2F1115waiverrenewal.
41. Ibid.
42. Ibid.
43. New York State Department of Health Office of Health Insurance Programs, “Continuous eligibility waiver amendment,” New York State Department of Health (2024), https://www.health.ny.gov/health_care/medicaid/redesign/med_waiver_1115/docs/draft_amend_request.pdf.
44. Jonathan Ingram, “Hochul wants to create a middle-class Medicaid entitlement New York can’t afford,” New York Post (2024), https://nypost.com/2024/02/14/opinion/hochul-wants-to-create-a-middle-class-medicaid-entitlement-new-york-cant-afford.
45. New York State Department of Health Office of Health Insurance Programs, “Continuous eligibility waiver amendment,” New York State Department of Health (2024), https://www.health.ny.gov/health_care/medicaid/redesign/med_waiver_1115/docs/draft_amend_request.pdf.
46. Kate Lisa, “Proposed Medicaid cuts hang in N.Y. budget balance,” Spectrum News (2024), https://spectrumlocalnews.com/nys/central-ny/politics/2024/04/15/proposed-medicaid-cuts-hang-in-n-y–budget-balance.
47. U.S. Department of Health and Human Services, “Fiscal year 2025 budget in brief,” U.S. Department of Health and Human Services (2024), https://www.hhs.gov/sites/default/files/fy-2025-budget-in-brief.pdf.
48. Ibid.
49. Ibid.
50. Jonathan Ingram and Sam Adolphsen, “Stopping the Medicaid madness: How Congress and states can start salvaging some program integrity,” Foundation for Government Accountability (2022), https://thefga.org/research/stopping-the-medicaid-madness-how-congress-and-states-can-start-salvaging-some-program-integrity.
51. Centers for Medicare & Medicaid Services, “Eligibility and enrollment processing for Medicaid, CHIP, and BHP during COVID-19 Public Health Emergency unwinding key requirements for compliance,” U.S. Department of Health and Human Services (2022), https://www.medicaid.gov/resources-for-states/downloads/eligibility-enrollment-rules.pdf.
52. Centers for Medicare & Medicaid Services, “Medicaid/CHIP eligibility verification plans,” U.S. Department of Health and Human Services (2024), https://www.medicaid.gov/medicaid/eligibility/medicaidchip-eligibility-verification-plans/index.html.
53. Peter Frost, “Quinn signs Illinois Medicaid expansion bill,” Chicago Tribune (2013), https://www.chicagotribune.com/2013/07/22/quinn-signs-illinois-medicaid-expansion-bill-2.
54. Illinois Department of Healthcare and Family Services, “Medical and managed care enrollment by month,” State of Illinois (2023), https://hfs.illinois.gov/content/dam/soi/en/web/hfs/sitecollectiondocuments/202307hb2731.pdf.
55. Hayden Dublois and Jonathan Ingram, “Ineligible Medicaid enrollees are costing taxpayers billions,” Foundation for Government Accountability (2022), https://thefga.org/research/ineligible-medicaid-enrollees-costing-taxpayers-billions.
56. Centers for Medicare & Medicaid Services, “Medicaid/CHIP eligibility verification plans,” U.S. Department of Health and Human Services (2024), https://www.medicaid.gov/medicaid/eligibility/medicaidchip-eligibility-verification-plans/index.html.
57. Centers for Medicare & Medicaid Services, “Medicaid and CHIP renewals: Returning to regular operations,” U.S. Department of Health and Human Services (2024), https://www.medicaid.gov/resources-for-states/coronavirus-disease-2019-covid-19/unwinding-data-reporting/index.html.
58. Tami Luhby, “These 5 states will be the first to kick residents off Medicaid starting in April,” CNN (2023), https://www.cnn.com/2023/04/01/politics/medicaid-termination-states/index.html.
59. Chelsea Cirruzzo, “Biden administration pleads with states after millions of kids lose Medicaid coverage,” Politico (2023), https://www.politico.com/news/2023/12/18/biden-administration-pleads-with-states-after-millions-of-kids-lose-medicaid-coverage-00132282.
60. Centers for Medicare & Medicaid Services, “State option to delay procedural disenrollments,” U.S. Department of Health and Human Services (2023), https://www.medicaid.gov/resources-for-states/coronavirus-disease-2019-covid-19/unwinding-and-returning-regular-operations-after-covid-19/state-option-to-delay-procedural-disenrollments/index.html.
61. Arkansas Department of Human Services, “Arkansas Department of Human Services releases June report on Medicaid unwinding,” State of Arkansas (2023), https://humanservices.arkansas.gov/news/arkansas-department-of-human-services-releases-june-report-on-medicaid-unwinding/.
62. McCourt School of Public Policy Center for Children and Families, “What is happening with Medicaid renewals in each state?,” Georgetown University (2024), https://ccf.georgetown.edu/2023/07/14/whats-happening-with-medicaid-renewals.
63. Centers for Medicare & Medicaid Services, “Extension of temporary unwinding-related flexibilities,” Centers for Medicare & Medicaid Services (2024), https://www.medicaid.gov/federal-policy-guidance/downloads/cib050924-e14.pdf.
64. Ibid.
65. Ibid.
66. Ibid.
67. Ibid.
68. Ibid.
69. Ibid.
70. Jonathan Bain, “Medicaid mismanagement: How states can restore integrity to the program while saving taxpayers billions,” Foundation for Government Accountability (2023), https://thefga.org/research/medicaid-mismanagement-states-can-restore-integrity.
71. Ibid.
72. Ibid.
73. Ibid.
74. Ibid.