The Center for Medicaid and Medicare Services (CMS) has identified a Medicaid unwinding compliance issue with “ex parte” (automatic or passive) renewals that has impacted more than half the states in the country. Specifically, CMS found that many states were conducting ex parte renewals at the household level instead of the individual level as required by federal law.

Ex parte is an important protective feature of Medicaid eligibility as it is intended to reduce the burden of completing renewal applications on the programs’ members.  It requires that states attempt to determine ongoing eligibility based on electronic data sources available to them before reaching out to members to request information. It is often very effective but given the complex personal circumstances of Medicaid members, ex parte cannot always be used.  When that happens, a manual renewal is requested.

Connecticut initiates renewals at the household level, meaning if someone in the household cannot be ex parte renewed, a request to complete a manual renewal is sent.  While it’s acceptable for states to wait for a response to the manual renewal as updated information may appropriately impact other household members’ eligibility, a lack of response to the manual renewal should not cause the closure of other individuals in the household who appear to qualify based on data from electronic data sources.  Connecticut has identified approximately 26,000 individuals out of over 1.2 million HUSKY recipients since April 2023 who were disenrolled because another household member did not respond to the manual renewal.

In response to CMS and to comply with federal requirements, Connecticut is taking action to ensure all eligible individuals remain covered:

• In September 2023, DSS implemented system changes to prevent eligible individuals from being disenrolled in the future when other household members have not completed their renewal.
• In November 2023, individuals who were previously eligible based on ex parte renewal but closed between April 2023 and August 2023 because the household failed to complete the manual renewal, will be reinstated to eliminate any gap in coverage.
  • Individuals will receive a notice and instructions about how to submit claims or be reimbursed for Medicaid covered services obtained during the period for which they should have been enrolled in Medicaid.