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Medicaid warned states Wednesday that they could be mistakenly removing children from government insurance programs in a post-pandemic review of millions of enrollees.

States may be unnecessarily disenrolling children from Medicaid or the Children’s Health Insurance Program because they are reviewing families as a whole despite there being a higher threshold to remove children from the programs.

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“Children in pretty much every state have higher income eligibility thresholds than their parents, making them much more likely to still remain eligible for Medicaid, even if their parents no longer qualify,” Medicaid Director Daniel Tsai told reporters.

Tsai repeatedly declined to say how many states are experiencing the issue or how many children could be affected.

“Many states in discussions are in the midst of trying to determine if they have this issue or not,” he said. “We’re not sitting around waiting for everybody to assess things before we take action.”

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States have disenrolled more than 5.5 million people since the pandemic freeze on Medicaid ended this spring. Seventy-four percent of those people have been removed because they did not complete the renewal process, according to data from the nonprofit KFF. Those cases, known as procedural removals, can occur because people have outdated contact information or believe they are no longer eligible — even if their children might be.

But data on how many children are losing medical insurance are extremely limited so far. Only 15 states have reported disenrollments by age, and between them nearly 1.5 million children have been removed, said Jennifer Tolbert, director of the state health reform and data for KFF. It is not clear how many of those were for procedural reasons.

Medicaid issued letters to all 50 states, ordering them to review their renewal process for the glitch.

The agency has previously declined to publicly name states that are not in compliance with redetermination processes, but Tsai said earlier this month that officials paused terminations in “half a dozen” states to review potential errors.

He also said in July that Medicaid is in “collaborative discussions” with Montana about implementing waivers to let eligible people auto-renew their insurance.

A CMS spokesperson told STAT Wednesday that “following strong encouragement and discussions between CMS and Montana’s Medicaid agency the state adopted two of our strategies.”

That leaves Florida as the only state that has not adopted any Medicaid enrollment waivers.

If that occurs, “there would only be one state across the country that has not taken up any of the many policy waivers and flexibilities we have put out,” Tsai said then. He declined to name the one state, but policy and health care advocacy groups have publicly called out Florida.

Analysts will have a more complete picture of how many children have been affected next month when states finish assessing their eligibility systems, Tolbert said.

However, disenrollments are likely to continue. Eleven states only began the renewal process in July; 20 states and the District of Columbia started in June, while others began in the spring. One state, Oregon, will not start until this October.

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