Tracking Texas Medicaid & SNAP Paperwork Delays
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 a self-imposed, 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.
We’re following key unwinding updates month by month. Every Texan’s Tracker was last updated December 5, 2023.
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 how 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 and 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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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)
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.
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.
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.
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.”
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.
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.
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).