April 24, 2024
Tracking Texas Medicaid & SNAP
Application Delays & Benefit Backlogs
Too many Texans can't get Medicaid and SNAP, despite being eligible.
An effective Medicaid and SNAP eligibility and enrollment system forms the foundation for meeting food and health care needs of eligible, low-income Texans. Its most basic function is to process eligibility accurately and without delay. Texas’ crisis-ridden system is doing neither. When our eligibility system fails, Texas loses out on billions of federal dollars that fuel our state and local economies, and hard-working, low-wage Texas families face food insecurity and barriers to health care.
Every Texan’s tracker highlights key developments related to Texas’ strained eligibility system as Texas re-checks eligibility for all 6 million Texans with Medicaid, following a nationwide pause on disenrollments during the pandemic. This process is referred to as Medicaid unwinding.
This is an enormous undertaking for Texas’ Medicaid and SNAP eligibility and enrollment system. Yet, the Legislature failed to fully fund the effort, and Governor Abbott has failed to address paperwork backlogs and coverage losses for eligible kids, seniors, and individuals with disabilities. Texas started the process behind because of an eligibility worker shortage, Medicaid and SNAP paperwork backlogs, and an unrealistic timeline that crammed too many Medicaid renewals into too few months.
Millions of Texans, mostly children of color in low-income families, are at risk of losing their health insurance despite remaining eligible for Medicaid and are also unable to get their SNAP applications processed on time. As the system failures continue, the hardships faced by Texans applying for Medicaid and SNAP have worsened.
Texas Unwinding Timeline
We’re following key unwinding updates month by month. Every Texan’s Tracker was last updated June 25, 2024.
June
June 10
CMS and the US Department of Agriculture (USDA) have sent Texas four separate letters in recent weeks requesting data on the Medicaid and SNAP backlogs, delays, errors, and warning of action at the federal level (including the loss of federal funding) if the state does not improve and come into compliance with federal law.
Read the letter from CMS here. View the three separate warnings from USDA here, here, and here. Texas is required to respond within 30 days to each letter.
The letter from CMS urges Texas to fix the continued delays in Medicaid application processing time and backlogs. CMS states they will be conducting a focused review of the state’s Medicaid and CHIP eligibility determinations at application and have requested additional information including:
- The number of Medicaid applications pending and the age of the pending applications (to be continued monthly);
- A staffing plan including the number of staff currently processing Medicaid and CHIP applications;
- A staff training plan containing the number of staff still in need of training and a timeline for this to be completed;
- A list of interventions or strategies the state has implemented to address the backlog; and
- A process map showing the state’s workflow for processing applications, including a description of any automated IT system functionality.
This information must be submitted to CMS within 30 days.
The letters from USDA, dated May 21, 2024, are regarding the state’s continued timeliness issues with SNAP applications and backlogs. As of May 24, there were over 48,000 SNAP applications in the backlog. The letters also state that USDA has not approved HHSC’s Corrective Action Plan, which has now been resubmitted by the state three times, as it was deemed insufficient and did not show a root cause for the low timeliness application rate.
USDA also found that Texas is out of compliance with work requirements and time limits in the SNAP program. The Fiscal Responsibility Act of 2023 increased the age of SNAP participants who are subject to the Able-Bodied Adults Without Dependent (ABAWD) work requirements and time limits and added new groups of individuals who are exempted from these requirements. State agencies were required to implement these changes beginning September 1, 2023. Additionally, effective Oct. 1, 2023, the same bill increased the age of those subject to the ABAWD time limit and work requirements to age 52 and required states to apply age-based exceptions to new applications received as of Oct. 1, 2023.
HHSC notified the Food and Nutrition Service (FNS) it had implemented the required policy changes to ensure eligible SNAP clients did not improperly lose benefits while the system changes were finalized. However, FNS found in January 2024 that HHSC was not properly screening SNAP applications for exceptions to the ABAWD requirement, clients are not being properly informed, and several cases in which discretionary exemptions should have been applied to the client and were not.
Finally, a letter from USDA to HHSC dated April 29, 2024, states HHSC is out compliance with USDA regulations as it relates to the SNAP Employment and Training Program, including failure to provide support and source documents for costs incurred by the Employment and Training program. HHSC also failed to comply with a corrective action plan to address the non-compliance initially. The letter asks HHSC to immediately validate that all federal SNAP spending related to the Employment and Training program are reasonable, necessary, and directly related to the program. If HHSC cannot provide evidence within 30 days that they are complying with all federal fiscal requirements, federal funding for SNAP in the amount of over $8 million will be disallowed and federal SNAP employment and training funds could be suspended. HHSC’s response can be found here, including an updated corrective action plan.
Texas Congressman Rep. Lloyd Doggett has issued a press statement on the letters here.
May
May 30
CMS announced it will require states to continue to release monthly Medicaid renewal data, even after their Unwinding process is over. This is a great win for continued transparency into the Medicaid and CHIP programs in Texas! As described in the linked letter, state reporting on Medicaid renewal outcomes will continue after the Consolidated Appropriations Act 2023 requirements end on June 30, 2024. CMS will continue to report state and national data publicly to continue providing transparency into Medicaid and CHIP eligibility and enrollment processes as well as individuals’ ability to renew their coverage.
May 2
Georgetown Center for Children and Families published a report today on the change in child Medicaid enrollment since the unwinding began. There is a wide variation in child disenrollment levels by state, due to state policy choices and approaches to the unwinding. The report found that:
- Texas, Florida, Georgia, and California saw the largest number declines in Medicaid/CHIP child enrollment, accounting for half of the total national decline.
- Texas accounts for nearly one quarter of the child Medicaid/CHIP enrollment decline during unwinding
- Texas leads the way by far in the number of children disenrolled from Medicaid, topping 1 million, followed by Florida (nearly 600,000), Georgia (more than 300,000) and California (nearly 200,000).
Due to Texas’ rushed unwinding timeline, our high levels of procedural denials, and extremely low ex-parte rates, these numbers are not surprising but should be a call to action to ensure eligible children are re-enrolled in a timely fashion or given another door to health care coverage.
April
April 24
A brief published today by the Perryman Group estimates the economic costs of the disenrollment of over 2 million Texans from Medicaid since the unwinding began a year ago. The Group estimates the economic costs of decreasing the number of Texans covered by health insurance by 2.1 million to be:
- A state loss of $58.9 billion in annual gross product and almost 509,200 jobs (if the situation persists)
- Of that amount, $29.3 billion in yearly gross product and 281,100 jobs are due to decreased health-related spending; and
- $4.8 billion in annual gross product and 36,500 jobs lost due to increased uncompensated care; and
- Another approximately $24.9 billion in annual gross product and 191,600 job losses are due to decreased productivity.
The brief argues, as the number of uninsured continues to rise as a result of the unwinding, health related spending decreases, the level of uncompensated care rises, and higher levels of uncompensated care result in rising insurance premiums, in addition to decreased productivity caused by an increase in negative health outcomes for those left without access to care.
April 18
The Texas Health and Human Services Commission (HHSC) posted its April unwinding report, a monthly report required by the federal Centers for Medicare and Medicaid Services (CMS) that includes data for March. HHSC also posted its March End of Continuous Medicaid Coverage Dashboard report that contains some additional detail with data through March 11, 2024. The reports show:
- Texas’ cumulative ex parte renewal rate from April 2023 – March 2024 is just 3.7%. Texas continues to have the worst ex parte renewal rate in the nation. The ex parte process utilizes data matching to confirm ongoing eligibility. Ex parte renewals help the state improve accuracy, reduce burden on the strained eligibility system, and help eligible Texans stay covered.
- As of the end of March, HHSC had a backlog of more than 18,000 Medicaid applications submitted in March 2023 or earlier that still have not been processed. These applications have been waiting for at least 12 months, significantly longer than the 45-day federal timeline for processing Medicaid applications. HHSC is not required to report on backlogged Medicaid applications submitted since April. As of March 29, 2024, there were 208,129 Medicaid applications backlogged and the median number of days to process a new Medicaid application was 88 days. Less than half of new Medicaid applications are now being processed within the federal standard processing time.
- From April 2023 to March 2024, a total of 1.37 million Texans – most of whom are children – were removed from Medicaid for procedural reasons, meaning they didn’t complete every step in the renewal process and their Medicaid coverage was terminated, even though HHSC never confirmed whether or not they remained eligible. As of March 12, the KFF state unwinding data tracker shows Texas has the sixth worst procedural denial rate in the nation. Procedural denials often happen when the state sends renewal paperwork to the wrong address or people encounter other barriers related to paperwork, the call center, or the online portal. Another 695,489 Texans have been removed from Medicaid because HHSC determined they were no longer eligible, bringing the total unwinding removals in Texas to over 2 million from April 2023 to mid March 2024.
As of March 11, 2024, 1.35 million children have lost Medicaid coverage during the unwinding process. Children are eligible for Texas Medicaid/CHIP at higher income levels and are likely to remain eligible at renewal. Experts project that 3 in 4 kids who lose Medicaid during unwinding will, in fact, still be eligible, and that kids of color are most at risk of losing Medicaid during unwinding despite remaining eligible.
March
March 13
The Texas Health and Human Services Commission (HHSC) posted its March unwinding report, a monthly report required by the federal Centers for Medicare and Medicaid Services (CMS) that includes data for February. It also posted its February End of Continuous Medicaid Coverage Dashboard report that contains some additional detail with data through February 20, 2024. The reports show:
- Texas’ cumulative ex parte renewal rate from April 2023 – February 2024 is just 3.4%. Texas continues to have the worst ex parte renewal rate in the nation. The ex parte process utilizes data matching to confirm ongoing eligibility. Ex parte renewals help the state to improve accuracy, reduce burden on the strained eligibility system, and help eligible Texans stay covered.
- As of the end of February, HHSC had a backlog of more than 21,000 Medicaid applications submitted in March 2023 or earlier that still have not been processed. These applications have been waiting for at least 11 months, significantly longer than the 45-day federal timeline for processing Medicaid applications. HHSC is not required to report on backlogged Medicaid applications submitted since April. As of March 1, 2024, there were 232,685 Medicaid applications backlogged and the median number of days to process a new Medicaid application was 79 days.
- From April 2023- February 2024, a total of 1.38 million Texans – most of whom are children – were removed from Medicaid for procedural reasons, meaning they didn’t complete every step in the renewal process and their Medicaid coverage was terminated, even though HHSC never confirmed whether or not they remained eligible. As of March 12, the KFF state unwinding data tracker shows Texas has the fifth worst procedural denial rate in the nation. Procedural denials often happen when the state sends renewal paperwork to the wrong address or people encounter other barriers in the process related to paperwork, the call center, or the online portal. Another 701,938 Texans have been removed from Medicaid because HHSC determined they were no longer eligible, bringing the total of unwinding removals in Texas to over 2 million from April 2023-mid February 2024.
- As of February 20, 2024, 1.34 million children have lost Medicaid coverage during the unwinding process. Children are eligible for Texas Medicaid/CHIP at higher income levels and are likely to remain eligible at renewal. Experts project that 3 in 4 kids who lose Medicaid during unwinding will, in fact, still be eligible, and that kids of color are most at risk of losing Medicaid during unwinding despite remaining eligible.
March 12
On March 12, 2024, the National Health Law Program (NHeLP), Disability Rights DC at University Legal Services (DRDC) and Disability Rights Texas (DRTx), filed two complaints with the Department of Justice and the U.S. Department of Health and Human Services Office for Civil Rights alleging violations of the Americans with Disabilities Act in the Medicaid renewal process in the District of Columbia and Texas. The Texas complaint alleges Texas Medicaid does not meet the needs of Medicaid enrollees who receive home and community-based services (HCBS), as the Texas renewal process does not utilize existing information to automatically renew individuals coverage, forcing the individual to go through an administratively burdensome process. The complaint also alleges the 211 call center in Texas provides incorrect information to people with disabilities. Read the full Texas complaint here.
March 5
On March 5, 2024, Senate Finance Committee Chair Ron Wyden and House Energy and Commerce Committee Ranking Member Frank Pallone sent a letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brookes- LaSure, requesting further information on how CMS is helping states correct unwinding-related eligibility and enrollment system issues that have surfaced in Medicaid and CHIP during the unwinding process. The letter identifies state areas of noncompliance, including failures to process applications in a timely manner and to automatically renew eligibility even when a state has the data needed to do so. The letter requests detailed state plans to fix these issues be made public and requests CMS continue to require and publish states monthly reports of eligibility and enrollment data, currently required under the Consolidated Appropriations Act of 2023, but ending in June 2024. The Congressional members requested a response from CMS by March 29, 2024.
February
Feb 12
The Texas Health and Human Services Commission (HHSC) posted its February unwinding report, a monthly report required by the federal Centers for Medicare and Medicaid Services (CMS) that includes data for January. It also posted its January End of Continuous Medicaid Coverage Dashboard report that contains some additional detail with data through January 9, 2024. The reports show:
- Texas’ cumulative ex parte renewal rate from April 2023 – January 2024 is just 3.2%. As of January 22, the national average is ten times higher (32%), and Texas has the worst ex parte renewal rate in the nation. The ex parte process utilizes data matching to confirm ongoing eligibility. Ex parte renewals help the state to improve accuracy, reduce burden on the strained eligibility system, and help eligible Texans stay covered.
- As of the end of January, HHSC had a backlog of more than 38,000 Medicaid applications submitted in March 2023 or earlier that still have not been processed. These applications have been waiting for at least 10 months, which is significantly longer than the 45-day federal timeline for processing Medicaid applications. HHSC is not required to report on backlogged Medicaid applications submitted since April. There were 188,729 Medicaid applications backlogged as of January 26.
- From April 2023-January 2024, 1.22 million Texans – most of whom are children – were removed from Medicaid for procedural reasons. That means they didn’t complete every step in the renewal process and their Medicaid coverage was terminated, even though HHSC never confirmed whether or not they remained eligible. As of February 1, the KFF state unwinding data tracker shows that Texas has the tenth worst procedural denial rate in the nation. Procedural denials often happen when the state sends renewal paperwork to the wrong address or people encounter other barriers in the process related to paperwork, the call center, or the online portal. Another 611,392 Texans have been removed from Medicaid because HHSC determined they were no longer eligible, bringing the total of unwinding removals in Texas to 2 million from April 2023-mid January 2024.
Of the 1.22 million Texans removed from Medicaid for procedural reasons, more than 1 million (or 82%) are children. Children are eligible for Texas Medicaid/CHIP at higher income levels and are likely to remain eligible at renewal. Experts project that 3 in 4 kids who lose Medicaid during unwinding will, in fact, still be eligible, and that kids of color are most at risk of losing Medicaid during unwinding despite remaining eligible.
Feb 9
On February 9, the National Immigration Law Center (NILC) filed a multi-state complaint with the Department of Health and Human Services Office for Civil Rights (OCR) and Centers for Medicare and Medicaid Services (CMS). The complaint alleges that at least 13 states are systematically failing to provide individuals with Limited English Proficiency (“LEP”) reasonable language assistance they need to participate in redeterminations of their Medicaid eligibility during the unwinding process.
Texas’ portion of the complaint includes:
- Texas has not met the language needs of several LEP populations during unwinding.
- HHSC is failing to provide individuals with LEP meaningful access to its call centers.
- YourTexasBenefits does not provide reliable in-language information to most LEP individuals.
This is also consistent with a recent Protecting Immigrant Families (PIF) Medicaid Unwinding survey and letter to CMS. Every Texan advocated for improved language access in HHSC programs during the recent legislative session, including a bill that would direct the agency to develop a language access plan.
Feb 8
On February 8, Agriculture Secretary Tom Vilsack issued a letter to 47 Governors, including Texas Governor Greg Abbott, expressing concerns with the timely and accurate processing of Supplemental Nutrition Assistance Program (SNAP) benefits in Texas. As we have reported for months, Texas continues to face delays and backlogs in processing SNAP benefits applications and redeterminations, leaving families without access to food. As of January 26, 119,000 SNAP applications were backlogged and sitting in a queue, and 33% of new SNAP applications were delayed beyond the 30-day federal processing deadline.
The letter urges Governor Abbott to prioritize timely and accurate application processing for SNAP benefits. The most recent state data shows Texas has an application processing timeliness rate of 87.08%; Anything above 95% is considered acceptable. Texas is also underperforming in the case and procedural error rate, which monitors inaccurate denials, terminations, or suspensions of a household’s SNAP benefits. Families should not lose access to critical food benefits because of state agency delays and inaccurate processing of applications.
In the letter, the U.S. Department of Agriculture offers to work with Texas to implement options available under current federal law to make accessing and keeping SNAP benefits easier for families. Suggestions include increasing the certification period for a household so that families can keep their benefits for a longer period of time before they are forced to renew. Texas currently requires households to recertify their SNAP benefits every six months. Increasing certification periods would reduce the administrative burden on families and agency staff, helping them to climb out of the application backlog they’ve been facing for months.
Feb 5
The U.S. Department of Agriculture announced the Summer Electronic Benefits Transfer program will become a permanent state option beginning Summer 2024. This program allows states to provide low-income families with funds during the summer months to help cover the cost of groceries while children are out of school. The Summer EBT program helps to fight the food insecurity children can face when school is not in session. States had until January 1, 2024 to let the federal government know if they would participate in the program this summer. More than 30 states have opted-in to the Summer EBT program for 2024, but Texas is not one of them.
With the ongoing delays in processing SNAP applications for families, not opting into the Summer EBT program is a missed opportunity that could benefit Texas families and about 3.7 million Texas children. Implementing this program in Texas will require collaboration between the Texas Education Agency, the Department of Agriculture, and the Health and Human Services Commission, with the majority of the workload falling on the already overly burdened HHSC. HHSC has indicated current resource constraints at the state agency level, the level of effort needed to implement the program, and new appropriations needed from the legislature (states are required to fund 50% of the program administrative costs) made 2024 implementation not feasible. Texas will have an opportunity to implement Summer EBT in 2025 and Every Texan will advocate for HHSC to have all of the resources it needs from the legislature and the processes in place to implement this important program.
January
Jan 31
The Texas Health and Human Services Commission (HHSC) posted its January End of Continuous Medicaid Coverage Dashboard report, a cumulative report that offers the most comprehensive picture we have to date of the Medicaid unwinding process. The latest update contains data from the beginning of the unwinding, April 1, 2023, through January 9, 2024. The report shows that Texas has reached an unfortunate milestone in the unwinding:
- Over 2 million Texans have now lost their Medicaid coverage since the start of unwinding;
- 1.33 million children have lost Medicaid; and
- More than 1 million children lost their Medicaid coverage due to procedural reasons, meaning they didn’t complete every step in the renewal process and their Medicaid coverage was terminated, even though HHSC never confirmed whether or not they remained eligible.
On January 31, the National Health Law Program (NHeLP), the Electronic Privacy Information Center (EPIC), and Upturn filed a formal complaint with the Federal Trade Commission (FTC) to investigate Deloitte Consulting regarding inaccurate and unreliable Medicaid eligibility determinations in Texas. The state’s automated eligibility system (known as TIERS) was developed by Deloitte. The complaint asks the FTC to look into concerns with TIERS, including: the unreliability of ex parte or administrative renewal redeterminations, failure to make accurate eligibility determinations, and the system reliably recognizing when requested documentation has been submitted.
Jan 16
The Texas Health and Human Services Commission (HHSC) posted its January unwinding report, a monthly report required by the federal Centers for Medicare and Medicaid Services (CMS) that includes data for December. It also posted its December End of Continuous Medicaid Coverage Dashboard report that contains some additional detail with data through December 13, 2023. The reports show:
- Texas’ cumulative ex parte renewal rate from April – December is just 2.9%. As of January 9, the national average is ten times higher (31%), and Texas has the worst ex parte renewal rate in the nation. The ex parte process utilizes data matching to confirm ongoing eligibility. Ex parte renewals help the state to improve accuracy, reduce burden on the strained eligibility system, and help eligible Texans stay covered.
- As of the end of December, HHSC had a backlog of more than 46,000 Medicaid applications submitted in March 2023 or earlier that still have not been processed. These applications have been waiting for at least 9 months, significantly longer than the 45-day federal timeline for processing Medicaid applications. HHSC is not required to report on backlogged Medicaid applications submitted since April.
- From April-December, a total of 1.2 million Texans – most of whom are children – were removed from Medicaid for procedural reasons, meaning they didn’t complete every step in the renewal process and their Medicaid coverage was terminated, even though HHSC never confirmed whether or not they remained eligible. As of January 9, the KFF state unwinding data tracker shows Texas has the eleventh worst procedural denial rate in the nation. Procedural denials often happen when the state sends renewal paperwork to the wrong address, or people encounter other barriers in the process related to paperwork, the call center, or the online portal. Another 592,261 Texans have been removed from Medicaid because HHSC determined they were no longer eligible, bringing the total of unwinding removals in Texas to 1.79 million from April-December.
- From April – December 13, 858,125 kids have been removed from Texas Medicaid without the state determining whether they are still eligible (a procedural denial). Children are eligible for Texas Medicaid/CHIP at higher income levels and are likely to remain eligible at renewal. Experts project that 3 in 4 kids who lose Medicaid during unwinding will, in fact, still be eligible, and that kids of color are most at risk of losing Medicaid during unwinding despite remaining eligible.
On December 18th, the Secretary of Health and Human Services, Xavier Becerra, sent letters to 9 states, including Texas, urging them to better protect children from losing access to Medicaid and CHIP. The 9 states called out (Texas, Arkansas, Florida, Georgia Idaho, Montana, New Hampshire, Ohio, and South Dakota) have the largest number or highest percentage of children who have lost Medicaid or CHIP coverage since the unwinding began. The letter urges states to ensure that no eligible child loses their healthcare coverage due to avoidable “red tape.”
Several proactive actions and policy changes are suggested to prevent eligible children from losing coverage, many of which Every Texan has been consistently advocating for over the last several months, including changes to the eligibility system to improve ex parte rates and section (e)(14) flexibilities to make renewals easier. Unfortunately Texas has only adopted four of these flexibilities, even though data show states that have pursued policy changes to make renewals easier have seen fewer children disenrolled from Medicaid and CHIP.
Data released by the federal government on the same day also reveals the states with the largest number of children losing Medicaid are states that have not expanded Medicaid. The 10 states (including Texas) that have not expanded Medicaid eligibility have disenrolled more children than all of the expansion states combined. The letter from HHS urges Texas to expand Medicaid, as thousands of youth with Medicaid or CHIP who turned 19 during the unwinding are now at risk of losing their healthcare coverage and falling into the coverage gap. Texas children are eligible to remain on Medicaid and CHIP until they turn 19. CMS estimates these youth account for about 27% of disenrollments among children during the unwinding in states that have not expanded Medicaid. Youth ages 19-25 in non-expansion states already had some of the highest uninsured rates of any group in the country prior to the pandemic. Unfortunately, it appears that the rates of uninsured young adults will continue to climb in Texas as the Governor and the Legislature refuse to expand Medicaid eligibility to low-income adults. Expanding Medicaid would ensure eligible young adults are able to maintain their healthcare coverage and ensure access to necessary preventative and behavioral healthcare services.
December
Dec 18
New federal data out today on children’s Medicaid and CHIP losses are a sobering illustration of how much state choices matter. States make countless choices to determine how easy or hard it is for families to keep their eligible kids covered during Medicaid unwinding renewals. Texas makes it far harder than it needs to be, causing lots of eligible kids to lose Medicaid, often due to red tape. Texas took up few of the federal options available to help eligible Texas kids maintain coverage during unwinding. When kids lose coverage, it puts at risk their ability to pick up their inhaler at the pharmacy counter, see their mental health provider, or avoid medical debt in an emergency. When eligible kids lose Medicaid due to red tape and have to reapply, their application can gather dust in an agency backlog for months because HHSC lacks the staffing, technology, and streamlining needed to process paperwork for Medicaid and SNAP accurately and without delay.
It’s been clear for months that Texas is ground zero for children’s Medicaid coverage losses nationwide. Sixty percent of Texans removed from Medicaid since April are children, many of whom likely remain eligible. New data from CMS shows that from April-September, net children’s Medicaid and CHIP enrollment in Texas has declined by 525,000 children, or a 12% decline. Texas alone accounts for 1 in 4 children who’ve lost Medicaid (net enrollment declines).
In addition, Texas HHSC’s data shows from April – November 10, shows Texas removed 909,000 children (gross) from Medicaid, nearly 80% of whom were removed for procedural reasons, meaning their family didn’t complete every step in the renewal process and their Medicaid coverage was terminated, even though HHSC never confirmed whether or not the child remained eligible. Procedural denials often happen when the state sends renewal paperwork to the wrong address or people encounter other barriers in the process related to paperwork, the call center, or the online portal. Children are eligible for Texas Medicaid/CHIP at higher income levels, and are likely to remain eligible at renewal. Experts project that 3 in 4 kids who lose Medicaid during unwinding will, in fact, still be eligible, and that kids of color are most at risk of losing Medicaid during unwinding despite remaining eligible.
Texas frontloaded its unwinding renewals and is now essentially done with the unwinding process. Texans are now up-to-date with their Medicaid paperwork. Just like before the pandemic, Texans with Medicaid have either proven they qualify or submitted paperwork that’s stuck in the state’s backlog.
Every Texan has called on Texas to take 2 immediate steps to reduce the workload coming into the eligibility system, so that HHSC can dig out of the backlogs, while ensuring that Texans in need can eat and access health care:
- Request an emergency waiver from the USDA Food and Nutrition Service to automatically extend SNAP benefits up for renewal by 6 months until backlogs are eliminated. Texas leveraged this same process, under different federal authority, several times over the last two years to help mitigate backlogs.
- Request a section 1902(e)(14)(A) waiver from the Centers for Medicare and Medicaid Services to delay children’s Medicaid renewals for 12 months for kids scheduled for renewal through March, the duration of Texas’ unwinding period. Kentucky and North Carolina have already received federal approval for this action due to workload and staffing challenges. Updated CMS guidance released today also highlights this option.
Dec 12
The Texas Health and Human Services Commission (HHSC) posted its December unwinding report, a monthly report required by the federal Centers for Medicare and Medicaid Services (CMS) that includes data for November. It also posted its November End of Continuous Medicaid Coverage Dashboard report that contains some additional detail with data through November 10, 2023. The reports show:
- Texas’ cumulative ex parte renewal rate from April – November is just 2.7%. As of December 7, the national average is ten times higher (31%), and Texas has the worst ex parte renewal rate in the nation. The ex parte process utilizes data matching to confirm ongoing eligibility. Ex parte renewals help the state to improve accuracy, reduce burden on the strained eligibility system, and help eligible Texans stay covered.
- As of the end of November HHSC had a backlog of more than 48,000 Medicaid applications submitted in March 2023 or earlier that still have not been processed. These applications have been waiting for at least 8 months, significantly longer than the 45-day federal timeline for processing Medicaid applications. HHSC is not required to report on backlogged Medicaid applications submitted since April.
- From April-November, a total of 1.1 million Texans – most of whom are children – were removed from Medicaid for procedural reasons, meaning they didn’t complete every step in the renewal process and their Medicaid coverage was terminated, even though HHSC never confirmed whether or not they remained eligible. As of December 7, the KFF state unwinding data tracker shows Texas has the fifth worst procedural denial rate in the nation. Procedural denials often happen when the state sends renewal paperwork to the wrong address or people encounter other barriers in the process related to paperwork, the call center, or the online portal. Another 557,000 Texans have been removed from Medicaid because HHSC determined they were no longer eligible, bringing the total of unwinding removals in Texas to 1.7 million from April-November.
- From April – November 10, 2023, 716,000 kids have been removed from Texas Medicaid, without the state determining whether they are still eligible (a procedural denial). Children are eligible for Texas Medicaid/CHIP at higher income levels, and are likely to remain eligible at renewal. Experts project that 3 in 4 kids who lose Medicaid during unwinding will, in fact, still be eligible, and that kids of color are most at risk of losing Medicaid during unwinding despite remaining eligible.
Dec 8
Backlog updates:
- HHSC told KXAN that 150,000 Medicaid applications were backlogged beyond the 45-day processing timeline as of November 27.
- Prior reporting of HHSC data from KXAN and the Statesman indicate that 138,000 SNAP applications are backlogged beyond the 30-day processing timeline as of November 23.
- Texas State Employees Union CWA Local 6186, Every Texan and Texans Together for Our Common Good released a joint statement urging Governor Abbott to take immediate action to resolve long delays eligible Texans face in accessing essential food and health care assistance due to HHSC backlogs.
Dec 1
Texas’ 12-month unwinding period started in April 2023 and technically extends through March 2024. However, as of December 1, Medicaid unwinding is essentially over in Texas. States had flexibility to distribute renewals during the unwinding period as they saw fit, so long as all renewals were initiated within 12 months. Texas chose to front-load renewals for Texans whose Medicaid coverage was maintained due to the federal continuous coverage provisions from April – September. The last procedural denials for this group happened on November 30, including individuals in Cohort 3, who received a 30-day extension to submit their renewal paperwork (see November 8 below).
As of December 1, no Texans are covered by Medicaid unless they were determined eligible within the previous 12 months or they took needed action to renew recently, but their paperwork is backlogged at HHSC. In other words, people with Texas Medicaid today are current with their paperwork and proof of eligibility, just like before the pandemic and federal continuous coverage provisions. All Texas Medicaid renewals initiated since October have been regular renewals–Texans who would have been covered regardless of the federal continuous coverage provisions.
Even though the narrow process of unwinding in Texas is over, the harms from the loss of Medicaid among eligible kids and long delays for SNAP and Medicaid paperwork remain. Texas’ rushed unwinding timeline designed to rapidly cull the program lacked adequate IT systems, streamlining, or staffing. Not surprisingly, this resulted in growing backlogs of paperwork and delays for SNAP and Medicaid and a high procedural denial rate in Medicaid. Texas unquestionably ended coverage for many Texans who remained eligible for Medicaid, primarily children.
November
Nov 23
News coverage of the fourth whistleblower letter on long waits for SNAP benefits (see November 21) revealed some new information:
- Governor Greg Abbott told KXAN News, “my office is working with the Texas Health and Human Services Commission to make sure that they fix any problem that is causing any delay whatsoever, because we want to make sure that the people who are eligible for SNAP are going to be getting the food that they deserve.”
- KXAN and the Austin American Statesman are reporting that HHSC aims to cut the SNAP backlog in half by the end of December by moving 250 staff from other tasks to focus on SNAP applications, and by training 600 newer eligibility workers in Medicaid over the next 5 months, so they can help process paperwork of people who apply for SNAP and Medicaid together.
- In a follow-up to KXAN, agency whistleblowers expressed skepticism that these steps would cut the backlog in half in a month. They said it takes two months or more to train a worker to process Medicaid applications. They also said is it “misleading” to imply that the 250 staff moved from other tasks are additional capacity because “they have been working on the same backlog for months.”
The Statesman reports that 138,000 SNAP applications are backlogged at HHSC. This figure appears to be just backlogged applications, and does not necessarily include SNAP renewals, which are also backlogged and could affect as many or more households.
Nov 22
Every Texan submitted recommendations to HHSC as it develops its Legislative Appropriations Request (LAR) for the 2026-2027 state budget. Our recommendations included several steps needed during the 2025 Texas legislative session to fix the eligibility system, ensure adequate staffing, streamline processing, and address barriers to enrollment.
We noted that immediate and meaningful action was needed, however, to address the current crisis in the eligibility system. Sizeable backlogs in the eligibility system are forcing eligible Texans in need to wait months for food and health care assistance, contributing to financial hardships, hunger, and delays in access to health care for low-income Texas children, pregnant women, the elderly, and individuals with disabilities. We called on Texas to immediately take the two steps below, to reduce the workload coming into the eligibility system, so that HHSC can dig out of the backlogs, while ensuring that Texans in need can eat and access health care:
- Request an emergency waiver from the USDA Food and Nutrition Service to automatically extend SNAP benefits up for renewal by 6 months until backlogs are eliminated. Texas leveraged this same process, under different federal authority, several times over the last two years to help mitigate backlogs.
- Request a section 1902(e)(14)(A) waiver from the Centers for Medicare and Medicaid Services to delay children’s Medicaid renewals for 12 months for kids scheduled for renewal through March, the duration of Texas’ unwinding period. Kentucky has already received federal approval for this action due to workload and staffing challenges.
Nov 21
A fourth whistleblower letter from anonymous Texas HHSC staff alleges that ongoing understaffing and unresolved system issues are contributing to growing delays for food assistance through SNAP as we approach the holidays. Whistleblowers allege that some Texans must now wait more than 180 days, or 6 months, from when they submit a SNAP application to when it is assigned to an eligibility worker for review. They reiterated their earlier projection that without meaningful state action to improve delays, the wait will grow to 200 days by the end of the year. Federal timeliness standards require that non-expedited SNAP applications be processed within 30 days.
Nov 10
The Texas Health and Human Services Commission (HHSC) posted its November unwinding report, a monthly report required by the federal Centers for Medicare and Medicaid Services (CMS), as well as its October End of Continuous Medicaid Coverage Dashboard report that contains some additional detail. The reports show:
- Texas’ ex parte (data-driven) renewal rate in October was an abysmal 0.5%, the lowest rate in any month so far during unwinding. Texas’ cumulative ex parte renewal rate from April – October is just 2.1%. As of November 14, the national average is fourteen times higher (30%), and Texas has the worst ex parte renewal rate in the nation.
- As of the end of October, HHSC still had a backlog of 50,000 Medicaid applications submitted in March 2023 or earlier that have not been processed. All but about 100 of the backlogged applications are subject to a 45-day federal standard for maximum processing times, yet have waited at least 7 months.
- From April-October, a total of 937,000 Texans – most of whom are children – were removed from Medicaid for procedural reasons, meaning they didn’t complete every step in the renewal process, and their Medicaid coverage was terminated, even though HHSC never confirmed whether or not they remained eligible. As of November 14, the KFF state unwinding data tracker shows Texas has the sixth worst procedural denial rate in the nation (33% of renewals end in procedural denials)
- From April – September 580,000 kids have been removed from Texas Medicaid, without the state determining whether they are still eligible (a procedural denial). Children are eligible for Texas Medicaid/CHIP at higher income levels, and are likely to remain eligible at renewal. Experts project that 3 in 4 kids who lose Medicaid during unwinding will, in fact, still be eligible, and that kids of color are most at risk of losing Medicaid during unwinding despite remaining eligible.
Nov 8
November 8 is the due date for Texans in “Cohort 3” to submit their paperwork for Medicaid renewals that HHSC initiated in September. “Cohort 3” includes renewals for Texans who did not apply or renew within the year leading up to unwinding, yet who HHSC anticipates likely remain eligible: children, seniors, or individuals with disabilities. Cohort 3 is the last batch of unwinding renewals in Texas – renewals for individuals whose coverage was maintained due to the Medicaid continuous coverage protections, initially linked to the COVID Public Health Emergency.
As noted below, Texas extended the deadline for Cohort 3 renewals for an additional 30 days and did additional outreach to people up for renewal during the extension. Texans in Cohort 3 who do not respond to their renewal notice by November 8, will be removed from the program via automated procedural denial and will lose Medicaid coverage at the end of November. HHSC will report outcomes for Cohort 3 renewals on its December 8 report to CMS. As of December 1, unwinding will essentially be over in Texas. At that point, Texans will be covered by Medicaid only if they were determined eligible within the previous 12 months or took needed action to renew recently, but their paperwork is backlogged at HHSC.
Nov 7
An Austin American Statesman story highlighted long delays getting newborns covered by Medicaid due to backlogs in HHSC’s eligibility system. The article indicates that it usually takes 7-10 days to enroll a newborn into Medicaid, but HHSC says that, in September, it took an average of 15-30 days. It appears, however, that many Texans are waiting far longer. The article profiles a mom who had Medicaid for pregnant women when she gave birth in June. She called HHSC’s call center 2 days later to report her baby’s name and birthdate, as instructed. Five months later her infant is still uninsured, and each time she calls HHSC’s call center she’s told, “we’re behind.” The article also indicates that only 40% of the newborn patients at People’s Community Clinic, a federally qualified health center in Austin, who should have Medicaid are enrolled, and the rest are waiting.
October
Oct 30
Texas HHSC posted its monthly “timeliness” data for October for both Medicaid and SNAP. Of the Medicaid and SNAP application and renewal paperwork HHSC finished processing in October, these data show the share HHSC completed on time and the share that was delayed beyond applicable program standards–generally 30 days for SNAP and 45 days for Medicaid. These data only tell us about paperwork HHSC finished processing during the month; they do not indicate how many applications/renewals are backlogged and were not completed in the month (or how long paperwork is sitting in backlogs). Other HHSC data (see below) point to sizeable and growing paperwork backlogs.
In October, while HHSC processed nearly 100% of Medicaid renewal paperwork on time, only 63% of the Medicaid applications it processed were done on time. Many Texans who were removed from Medicaid during unwinding for procedural reasons (not because they were determined ineligible) will reapply and may face delays, as could newly-eligible individuals, including newly pregnant women who’ll apply.
In October, only 74% of SNAP applications HHSC processed were completed on time. HHSC fell well short of the federal program standard that 95% or more of SNAP applications be processed on time. In October, only 63% of SNAP recertifications HHSC processed were done on time. When SNAP recertifications are delayed, benefits lapse, forcing struggling Texan families to choose between buying groceries or paying for rent, utilities, gas, etc. HHSC has struggled to process Medicaid and SNAP paperwork in a timely manner for more than a year and a half, well before unwinding increased the workload.
Oct 12
The Texas Health and Human Services Commission (HHSC) posted its October unwinding report, a monthly report required by the federal Centers for Medicare and Medicaid Services (CMS). It shows:
- From April – September, Texas only renewed 2.4% of people using the reliable data it already has on hand to verify ongoing eligibility (called an “ex parte” renewal). As of October 16, the national average is ten times higher (29%), and Texas has the worst ex parte renewal rate in the nation (see chart below).
- As of the end of September, HHSC had a backlog of 52,000 Medicaid applications submitted in March 2023 or earlier that still have not been processed. Almost all of the backlogged applications are subject to a 45-day federal standard for maximum processing times. About 100 are disability-related Medicaid applications, subject to a longer 90-day standard. All of these applications have been sitting for more than 180 days. The report does not indicate how many additional applications submitted since March are still waiting to be processed, so the true size of the backlog is likely far larger.
- From April – September, a total of 816,000 Texans were removed from Medicaid for procedural reasons, meaning they didn’t complete every step in the renewal process. Their Medicaid coverage was terminated, even though HHSC never determined whether or not they remained eligible. As of October 16, the KFF state unwinding data tracker shows Texas has the third worst procedural denial rate in the nation (46% of renewals end in procedural denials). When procedural denials occur, not only do eligible people lose Medicaid, but also the state does not transfer people to other health programs. That means kids aren’t moved from Medicaid to CHIP, and postpartum moms aren’t transitioned to HealthCare.Gov or Healthy Texas Women.
September
Sept 27
HHSC posted its September End of Continuous Medicaid Coverage Dashboard report that contains some additional information related to Medicaid renewals, beyond what is reported in required monthly unwinding reports to CMS. For example, it contains data on outreach activities and Medicaid renewal outcomes for non-disabled children and postpartum women who had Medicaid during their pregnancy. From April – August, 337,000 children successfully renewed Medicaid, while 623,000 had their coverage terminated. 508,000 children, or 51% of all kids up for renewal, were procedurally denied. It is likely that a relatively small share of individuals identified as “children” in these data qualified for Medicaid as a child (18 or under) during the pandemic continuous coverage period, but have since turned 19 and “aged out.”
Children are eligible for Texas Medicaid/CHIP at higher income levels, and are likely to remain eligible at renewal. It is alarming that more than half a million kids have been removed from Texas Medicaid, without the state determining whether they are still eligible. Experts project that 3 in 4 kids who lose Medicaid during unwinding will still be eligible, and kids of color are most at risk of losing Medicaid during unwinding despite remaining eligible.
Sept 26
The entire Texas Democratic delegation to the U.S. House of Representatives sent a letter to the U.S. Department of Agriculture, the federal agency that oversees the Supplemental Nutrition Assistance Program (SNAP), urging corrective action in response to long waits for SNAP paperwork processing. As the letter notes, Texas has failed to meet the federal 30-day standard for processing SNAP paperwork since July 2021, forcing struggling Texans to choose between buying groceries or paying for rent, utilities, gas, and the like.
Sept 19
The entire Texas Democratic delegation to the U.S. House of Representatives sent a second letter to CMS, the federal Medicaid agency, urging it to pause Medicaid procedural disenrollments in Texas while the state takes corrective action to come into compliance with federal Medicaid requirements. The letter notes both system errors that have caused 100,000 Texans to be wrongly removed from Medicaid and Texas’ “shockingly low” ex parte (or data-driven renewal) rate, at only 2.4%, one-tenth of the national average.
Sept 19
A third whistleblower letter from anonymous Texas HHSC staff alleges that ongoing understaffing and system errors have led to significant paperwork delays for Medicaid and SNAP, as well as Texans being removed from Medicaid in error. Whistleblowers allege that Texans must now wait more than 100 days from when they submit a SNAP application to when it is first picked up by an eligibility worker for review, and without state action to improve delays, the wait will grow to 200 days by the end of the year. Federal timeliness standards require that non-expedited SNAP applications be processed within 30 days. The letter references a 2009 federal lawsuit filed during the previous eligibility system crisis, with similarly long SNAP delays. Note that Texas uses the same eligibility system (state workers, computer systems, call center, local benefit offices, etc) to process eligibility for Medicaid, CHIP, SNAP, TANF and Healthy Texas Women, so workload, staffing, or system issues that cause delays in one program, can affect all programs, and the Texas families who rely on them.
Unlike with unwinding Medicaid renewals, when a SNAP recertification is delayed, benefits lapse, meaning that families who remain eligible will face terrible tradeoffs between buying groceries, paying rent, paying utility bills, etc., while they wait for the state to process paperwork.
The letter also alleges system errors that have caused some former foster youth and eligible immigrants to be wrongly denied, as well as delayed mailing of requests for information from Medicaid in both April and August. Depending on the request, Texans must respond to requests for information within either 10 or 30 days from the date the notice is printed (not from the day it is actually received), so delayed mailing can make it hard or impossible for Texans to take action by the state’s deadline.
Sept 11
The Texas Health and Human Services Commission (HHSC) posted its September unwinding report, a monthly report required by the federal Centers for Medicare and Medicaid Services (CMS). It shows:
- In August alone, another 203,000 Texans were removed from Medicaid for procedural reasons. They didn’t complete every step in the renewal process, and HHSC never determined whether or not they remained eligible. As of September 15, the KFF state unwinding data tracker shows Texas has one of the worst procedural denial rates in the nation – 38% of renewals end in procedural denials. Only 3 states performed worse. From April through August, a total of 654,000 Texans were procedurally denied. Not only do procedural denials mean eligible people losing Medicaid, but the state also does not transfer people to other health programs. That means kids aren’t moved from Medicaid to CHIP, and postpartum moms aren’t transitioned to HealthCare.Gov or Healthy Texas Women.
- From April to August, Texas only renewed 2.4% of people using the reliable data it already has (called an “ex parte” renewal). As of September 15, the national average is ten times higher (27%), and Texas has the second worst ex parte renewal rate in the nation.
- By the end of August, HHSC had a backlog of 54,000 Medicaid applications submitted in or before March that still have not been processed. Almost all of the backlogged applications are subject to a 45-day federal standard for maximum processing times. About 100 are disability-related Medicaid applications, subject to a longer 90-day standard. All of them have been sitting for more than 150 days. The report does not indicate how many additional applications submitted since March are still waiting to be processed, so the true size the backlog is likely much larger.
For more on HHSC’s September unwinding report to CMS, see Cover Texas Now.
Sept 11
Texas HHSC announced it will adopt an available federal option (#14 on this CMS list) to delay procedural denials for one month while conducting targeted outreach for “Cohort 3” renewals scheduled to go out on September 9. “Cohort 3” includes renewals for Texans who did not apply or renew within the year leading up to unwinding, and who HHSC anticipates likely remain eligible: children, seniors, or individuals with disabilities. (Note, many children were included in earlier Cohort 1 and 2 renewals as well). During the additional 30 days, HHSC will let Managed Care Organizations (MCOs) know who has not completed renewal paperwork, so MCOs can do outreach.
This option was one of the top recommendations made to HHSC from a group of 15 Texas organizations in response to alarming initial unwinding data (which showed a high procedural denial rate and a low ex parte renewal rate). As noted in the letter, a 30-day delay is not sufficient to reduce procedural denials on its own. Groups recommended that HHSC take additional steps to ensure both MCOs and Community Partner organizations (community organizations certified by HHSC to provide application assistance) are able to provide meaningful phone-based assistance, so that Texans can get help completing and submitting paperwork during the 30-day extension. HHSC secured a new waiver for MCO assistance, but HHSC indicated that the new waiver does not include a means for MCOs to capture a “telephonic signature.” That said, it appears MCOs cannot help clients complete and submit renewal paperwork by phone.
Sept 9
Texas initiated renewals for about 1 million Texans in September, including renewals for people in “Cohort 3.” “Cohort 3” includes renewals for Texans who did not apply or renew within the year leading up to unwinding, and who HHSC anticipates likely remain eligible: children, seniors, or individuals with disabilities. This is the last batch of renewals for individuals whose coverage was maintained due to the Medicaid continuous coverage protections, initially linked to the COVID Public Health Emergency. September is also the last month where HHSC will initiate a million renewals in one month, as it also did in April, July, and August (see timeline below). The tidal wave of Medicaid renewals Texas initiated in July-September will place additional strain on the already overburdened state work force and computer system that processes Medicaid and SNAP paperwork, further increasing delays. Starting in October, HHSC will only be initiating “regular” Medicaid renewals, for people who applied or renewed in the previous year.
Sept 5
Texas HHSC posted its monthly “timeliness” data for August, showing what share of Medicaid application and renewal paperwork it processes on time. Medicaid applications for children and pregnant women, for example, must be processed within 45 days. In August, while 99% of renewal paperwork was processed timely, only 76% of new Medicaid applications were. That leaves almost a quarter of all new Medicaid applications (including pregnant women who need immediate access to prenatal care) waiting more than 45 days. HHSC has struggled to efficiently process Medicaid paperwork for more than a year, well before unwinding increased the workload.
August
Aug 23
Texas HHSC posted alarming data showing unwinding coverage losses by children for the first time. 80% of Texans who’ve lost Medicaid in unwinding so far (April – July) are children; that’s around 500,000 kids without Medicaid. Medicaid unwinding will have an outsized impact on children, as 3 in 4 Texans with Medicaid are kids. Texas maintains very limited Medicaid eligibility for adults. About 42,000 Texas kids have transitioned from Medicaid to CHIP.
Children are eligible for Texas Medicaid/CHIP at higher income levels, and are likely to remain eligible at renewal. Alarmingly, nearly 400,000 kids have been removed from Texas Medicaid, without the state determining whether they were still eligible. Children, especially kids of color, are at the highest risk of losing Medicaid during unwinding despite remaining eligible.
Aug 22
The entire Texas Democratic delegation to the U.S. House of Representatives sent a letter to CMS urging it to pause Medicaid procedural disenrollments while Texas takes corrective action to come into compliance with federal Medicaid requirements.
Aug 21
A second whistleblower letter from Texas HHSC staff alleges additional system errors are booting eligible Texans, like newborns and pregnant women, off of Medicaid. The letter says these errors could jeopardize federal funds due to non-compliance, and they are not being addressed with systemic/IT fixes. The letter notes a newly-identified system error will incorrectly end coverage for hundreds or thousands of newborns on Medicaid in September, which is inconsistent with federal law that requires 12 months of continuous Medicaid coverage for newborns. The letter alleges that 5,800 pregnant women were booted off of Medicaid in error and were not given the required 2 months of postpartum coverage. These system issues raise concern over when the agency will be able implement HB 12, to extend postpartum coverage to 12 months.
The letter paints the picture of an eligibility system in crisis. Like the previous letter (July 25), this one implores agency leadership to provide IT resources needed to fix system errors that limit access to health and food benefits for eligible Texans and place an enormous strain on already-stretched HHSC staff to manually process workarounds and fix case-by-case. The letter notes that staff are on “persistent mandatory overtime with no apparent end in sight.” The letter says the “lead time” – the period from when a new application is submitted and when it is first touched by an eligibility worker – is an alarming 75 days, resulting in long waits for food and health benefits.
Aug 13
The Austin American Statesman editorial board calls on HHSC to “pause its disenrollment process immediately to ensure that as many Texas as possible who qualify to stay on Medicaid get a chance to renew before they are dropped.” The editorial points out the staggering number of Texans dropped without an eligibility determination. It also notes that while Virginia has renewed 66% of clients using state payroll and other data, Texas has used data-driven renewal in less than 1% of cases.
Aug 9
The federal Centers for Medicare & Medicaid Services (CMS) sent letters to all states reviewing data on their unwinding-related outcomes. CMS raised concerns about Texas’ high rate of procedural denials (disenrollments with no eligibility determination) and the state’s backlogs in processing Medicaid applications. See the Center on Budget and Policy Priorities for more context on these letters.
Aug 9
The Texas Health and Human Services Commission (HHSC) posted its August unwinding report, a monthly report required by the federal Centers for Medicare and Medicaid Services (CMS). Texas’ outcomes to date are far worse than most states. Texas’ monthly reports show that through the end of July:
559,952 Texans have been removed from Medicaid.
451,116 Texans lost Medicaid for “procedural” reasons, with no eligibility determination.
- Texas has a high procedural termination rate. 47% of all renewals to date have resulted in a procedural disenrollment. To date, only 3 states have a procedural disenrollment rate worse (higher) than Texas on the Georgetown Center for Children and Families (CCF) State Unwinding Renewal Data tracker: Nevada, South Carolina, and Utah (of all renewals due as of August 21, 2023).
- 4 in 5 Texans who’ve lost Medicaid to date had a procedural termination, with no eligibility determination. Only 1 in 5 (108,835 people), have been determined ineligible, enabling a transition to other coverage: CHIP, Healthy Texas Women or the Health Insurance Marketplace.
- Preventable, red-tape issues that contribute to procedural denials in Texas include:
- The state sending renewal paperwork to the wrong address;
- Clients blocked from accessing the online renewal system;
- Notices sent with multiple due dates or not in a client’s language;
- A call center that is closed on evenings and weekends, making it hard or impossible for Texans with inflexible jobs to get questions answered or renew by phone.
Texas has a remarkably low data-driven or “ex parte” renewal rate: 2.5% to date.
- Only two states perform worse in the CCF tracker to date: South Dakota and Wyoming (of all renewals due as of August 21, 2023). Arizona has fared best to date, processing 65% of its renewals using a data-driven process that takes the burden off of state workers and people with Medicaid.
- Data-driven renewals mean parents don’t have to fax, mail, or upload paycheck stubs when the state already knows what the family earns through state payroll data.
- A low data-driven renewal rate, like Texas’, means the state makes it harder than it needs to for eligible families to keep Medicaid.
212,419 Texans have renewed/retained Medicaid (20% of renewals to date)
Aug 4
The San Antonio Express News editorial board says that rather than plow ahead, Texas should pause the Medicaid disenrollments and then reevaluate the 400,000 people who may have lost coverage for bureaucratic reasons.
Aug 2
15 Texas organizations wrote to Texas HHSC urging specific actions to improve the state’s approach to unwinding and reduce unnecessary loss of coverage
July
July 28
Centers for Medicare & Medicaid Services (CMS) posted its first monthly unwinding data and performance indicator report for all states. It includes information on delays in processing Medicaid applications for children and pregnant women. Texas HHSC posts its “timeliness” data monthly, but the CMS report has nationwide data that allows state comparison. Texas is near the bottom with 39% of Medicaid applications taking more than 45 days to process in April, before unwinding dramatically increased the system’s workload. Only two states, Alaska and New Mexico, had a higher share of backlogged applications.
Despite notable efforts by HHSC to staff up, understaffing of eligibility positions and a lack of system/IT streamlining has resulted in delays in processing Medicaid and SNAP paperwork for more than a year.
July 25
A whistleblower letter from anonymous Texas HHSC staff alleges that 80,000 Texans, including pregnant women and seniors, were incorrectly removed from Medicaid due to system errors during the first wave of unwinding renewals initiated in April. HHSC later acknowledged the error and is working to reinstate coverage. The letter raises concerns that noncompliance with federal Medicaid requirements places Texas at risk of losing federal Medicaid funding. It also implores agency leadership to provide the IT resources needed to fix system errors that both limit access to health and food benefits for eligible Texans and place an enormous strain on already-stretched HHSC staff to instead manually process workarounds and case-by-case fixes.
July 20
In response to the alarming initial unwinding data from Texas, the Dallas Morning News editorial board called on state leaders to “temporarily halt procedural denials and take extra steps to make sure that recipients get an actual eligibility review instead of relying on missed deadlines and other procedural mistakes to prune the rolls.”
July 14
The Texas Health and Human Services Commission (HHSC) posted an updated June unwinding report, the first monthly report required by the federal Centers for Medicare and Medicaid Services (CMS) to show Texas unwinding renewal outcomes. Texas is off to a terrible start.
An alarming 81% of the 500,000 Texans removed from Medicaid in June were not actually determined ineligible. Rather, they lost coverage due to “procedural” issues, often red tape or paperwork problems that prevent families from completing all required steps like Texas sending their paperwork to an old address, confusing paperwork with multiple deadlines, and notices not in the family’s language.
For more information see Every Texan’s blog post and press statement, Children Defense Fund – Texas’ statement; Texans Care for Children’s statement; and Cover Texas Now’s blog post.
July 1
Texas has queued up a tidal wave of renewals for 3.6 million Texans – 60% of the Medicaid caseload – in July, August, and September. 3.6 million Texans is roughly equal to the full, pre-pandemic caseload of Texas Medicaid, renewals for whom would have been initiated over a full 12-month period. Cramming so many renewals into such a short period will further overwhelm Texas’ strained eligibility system, creating additional paperwork backlogs, longer waits for benefits, and long call center hold times. Texas advocates and stakeholders have urged the state to initiate renewals for no more than 11% (one-ninth) of the Medicaid caseload in any month, in line with federal guidance, to help ensure eligibility staff have time to process paperwork. Federal guidelines give Texas through March 2024 to initiate all Medicaid renewals (a 12-month unwinding period) and another two months, through May 2024, to complete processing those renewals.
On July 1 and August 1, renewal packets will go out to postpartum moms who gave birth more than 2 months ago. Even though the Legislature passed and the Governor signed House Bill 12, to extend postpartum Medicaid coverage from 2 months to a full 12 months, the coverage will not be in place until Texas submits a State Plan Amendment to CMS and gets federal approval. Most new moms who are more than 2 months postpartum will lose Medicaid by October.
April
April 8
Texas HHSC will begin sending renewal notices as part of “unwinding.” Renewals will be initiated for more than 1 million people in April (approximately 1/6 of the Medicaid caseload).