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DLS and MDH warn enrollment forecasts are volatile; audit raises questions about application processing

2381947 · February 24, 2025
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Summary

DLS and MDH told the subcommittee that recent system errors, pandemic-era renewal flexibilities and possible federal policy changes make Medicaid enrollment forecasts volatile and materially important to the FY26 budget.

The committee heard extended discussion about enrollment trends, the Medicaid redetermination process and federal uncertainty.

DLS analyst Anne Braun said Medicaid and MCHIP enrollment peaked at about 1,750,000 average participants in fiscal 2023 and had declined modestly in fiscal 24 and 25 amid the unwinding of pandemic-era protections. Braun said recent system errors and federal COVID-era renewal flexibilities paused some procedural disenrollments, and an audit of the Maryland Health Benefit Exchange (OLA) found that the exchange did not always request supporting documentation for applicants who attested to having no income; state wage records suggested some of those applicants reported incomes above Medicaid thresholds. DLS asked MDH and the exchange to describe corrective actions and whether ineligible applicants were disenrolled.

MDH Director Ryan Moran said the department and the exchange have identified differing enrollment and acuity dynamics and that DLS’s forecasts did not incorporate potential federal policy shifts because of high uncertainty. Moran warned that proposals in Congress to change the federal matching rate for the ACA expansion group, impose work requirements or shift Medicaid to a block grant or per-capita cap could dramatically raise state costs or reduce federal funding, although he noted the specific fiscal effects depend on the design of any federal proposal.

Why it matters: Enrollment assumptions drive Medicaid appropriations; errors in eligibility processing or unanticipated federal changes can shift millions of dollars in state costs and affect coverage for hundreds of thousands of residents.

DLS recommended reducing FY26 funding by $132,000,000 across Medicaid and MCHIP based on its enrollment forecast; MDH disputed lowering the FY26 enrollment baseline because of ongoing data volatility and recent increases in clinical acuity among remaining enrollees. Both agencies said they would continue to share monthly data and brief the committee. The committee also asked MDH to report back on corrective actions taken in response to the exchange audit and to reconcile disenrollments across systems.