Most Projected Medi-Cal Renewal Losses Stem From Preventable Paperwork Drop-Offs Rather Than Lost Eligibility
How our modeled renewal check splits form drop-offs among working and exempt adults from true income exits.
Every six months, counties check eligibility for adults enrolled in Medi-Cal expansion coverage. When work and reporting rules take effect, state systems check wage and benefit files first and mail paper renewal forms to everyone else.
When reviewing Medi-Cal renewal drops in a low-unemployment urban county like Santa Clara (0% jobless waiver share vs. high-unemployment waiver counties), one county total leaves out that 88.5% of expansion adults already work or hold an exemption.[1][2] In our modeled four-group check, 52.5% of projected disenrollment comes from avoidable form drops (14,219 of 27,076 per cycle), whereas flat state scaling projects 36,218 to 41,100 losses with no group split.[1][3] Splitting the renewal funnel by work hours and exemption type guides staff to exempt caregivers, disabled adults, and part-time workers.[2][3]
Table 1. Six-Month Renewal Funnel Across Four Medi-Cal Adult Groups
Group size, auto-match rates, and modeled form losses across four Santa Clara County groups.
| Group & Funnel Measure |
Group 1
Working ≥ 80 Hrs/Mo
|
Group 2
Rule Exemptions
|
Group 3
Gig & Part-Time Work
|
Group 4
No Recorded Work
|
|---|---|---|---|---|
| DHCS-Scaled Adult Count | 38.0%45,703 | 39.5%47,530 | 11.0%13,226 | 11.5%13,767 |
| Census Survey Adult Count | 50,934 | 52,971 | 14,752 | 15,341 |
| Auto Data Match Rate | 80.0% matched | 38.0% to 70.0% matched | 10.0% to 45.0% matched | 5.0% matched |
| Six-Month Plan Losses* | 13.9%6,367 | 19.9%9,435 | 38.8%5,138 | 44.6%6,136 |
| Avoidable Form Losses* | 35.0%2,228 | 72.4%6,831 | 64.6%3,319 | 30.0%1,841 |
| Main Renewal Form Hurdle | Wage lag or two jobs | Unlinked school or care forms | Hard 1099 or cash logs | Unlogged health or care hours |
Table 1 Notes & * Modeled Estimates
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Table 1 Notes & * Modeled Estimates: This six-month renewal funnel models 27,076 group losses per cycle. Of those, 14,219 (52.5%) are avoidable form drops. It is scaled to the June 2025 Santa Clara County DHCS count of 120,239 expansion adults. Group shares come from U.S. Census ACS 2019–2023 5-Year PUMS data (133,998 weighted adults, rounded to 134,000; n = 6,297 unweighted records across 15 PUMAs).
Column Scope. Working ≥ 80 Hrs/Mo. Regular W-2 wage earners. Rule Exemptions. Caregivers, disabled adults, and students. Gig & Part-Time Work. Self-employed and seasonal workers. No Recorded Work. No visible ACS survey exemption.
Two-Ruler Benchmark Summary. Calibrated Six-Month Renewal Funnel on Observed DHCS Baseline (120,239). Ruler 1: Flat-Share Aggregate Disenrollment View (County-Scaled Funnel): 36,218 to 41,100 / Cycle. Applying the flat 2.5949% state share to the DHCS state funnel projects 36,218 six-month losses. That rises to 41,100 with a 0% county jobless waiver share. It does not split form drops from lost eligibility. Ruler 2: Group Eligibility & Procedural Churn Ruler: 88.5% Eligible | 52.5% Avoidable. Census data (ACS 2019–2023 PUMS scaled to 120,239 DHCS adults) shows 77.5% work ≥80 hrs/mo or hold an exemption. Another 11.0% work part-time (88.5% total). Of 27,076 modeled losses, 14,219 (52.5%) are avoidable.
Visual Comparison: Total Six-Month Coverage Losses vs. Avoidable Form Losses (Adult Counts)
Separate paired horizontal bars (non-stacked) comparing total modeled six-month coverage losses (slate, Row 4) vs. avoidable paperwork losses among still-eligible adults (blue, Row 5).
Table 1 takeaway: Rule Exemptions have the largest volume of avoidable paperwork losses (6,831 of 9,435 total losses, or 72.4%), followed by Gig & Part-Time Workers (3,319 of 5,138, or 64.6%), Working >= 80 Hrs/Mo (2,228 of 6,367, or 35.0%), and No Recorded Work (1,841 of 6,136, or 30.0%).
Table 2. Group Profiles, Form Hurdles & County Actions
How county teams match each adult group to its main form hurdle and best fix.
| Decision Factor | Working ≥ 80 Hrs/Mo | Rule Exemptions | Gig & Part-Time Work | No Recorded Work |
|---|---|---|---|---|
| Work & Home Profile | W-2 retail, food, health, and warehouse workers (≥80 hrs/mo). | Parents, disabled adults, and students. | App drivers, home helpers, and seasonal part-time workers. | Jobless or family-care adults with no logged exemption. |
| What One Total Leaves Out | Pay file lags affect 20% who meet work rules. | State law exempts 100% of this group from work rules. | One-month checks skip valid hours over six months. | Unlogged health needs qualify for clinic exemptions. |
| County Staff Priority | Clear 80% by state wage files before outreach. | Accounts for 6,831 form drops per cycle. | Swap long tax logs for a one-page pay form. | Pair renewal calls with clinic checks and local slots. |
| Best County Action | Auto Wage Match + Text Upload. Clear 80% by wage data and add phone paystub upload. | Clinic & School Auto-Flag. Pre-fill health and care exemptions from clinic and school files. | Six-Month Rule + Short Form. Count any valid month in six plus simple cash forms. | Health Screen & Local Slot. Screen for health exemptions and link to local service slots. |
Table 2 Notes: Pre-Policy Baseline Drift & Local Unemployment Adjustment
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• Observed Pre-Policy Drift (DHCS Count): Santa Clara County expansion adult counts fell by -12.31% (-14,803 adults, from 120,239 in June 2025 to 105,436 in June 2026 in CHHS Open Data). That drop happened during routine unwinding before any work rule began.
• Zero Jobless Waiver Adjustment (Mode A): State DHCS funnel numbers subtract 373,389 adults in high-unemployment counties before paper checks (dhcs_verification_funnel_scc.csv:5). Santa Clara County has a low jobless rate (~4.1%). It gets a 0.0% county waiver share. Its paper check pool rises by +9,689 (from 72,437 to 82,126). At a 50% paper loss rate, county losses reach 41,100 per cycle instead of the flat-scaled 36,218.
• Phone Notice Upload Gain: Adding phone notice upload and form help stops 1,423 more DHCS-scaled losses (+3,131 on the ACS scale). Total stopped disenrollment rises from 14,219 to 15,642 of 27,076 (57.8%) on the DHCS scale. That equals 17,350 of 30,007 (57.8%) on the unscaled ACS base.
• Extended Cell Context. Work & Home Profile (Rule Exemptions). Parents (18,950), disabled adults (18,370), and students (10,210).
Compare Modeled Renewal Losses Across Three County Outreach Plans
Projected six-month Medi-Cal losses across three county plans on the 120,239 adult baseline.
With no help, half of adults sent paper forms after auto data checks lose coverage each six-month cycle.
Clinic and school auto-flags for caregivers and students plus a six-month hour check stop 71.4% of avoidable form drops.
Adding wage follow-up, health screens, and phone form upload across all four groups stops over half of six-month losses.
Scenario Calculations, Group Splits & ACS-Weighted Scale Crosswalk
Expand scenario notes
• Scenario 1 Base Counts: In the four-group model scaled to 120,239 DHCS adults, 54,152 reach paper renewal after auto checks. Of those, 27,076 (50.0%) lose plans each six-month cycle. That equals 30,174 on the 133,998 ACS 2019–2023 PUMS base, or 41,100 under flat state scaling with a 0.0% county jobless waiver.
• Scenario 2 Group Math: Auto clinic and school flags for exempt adults stop 6,831 modeled losses per cycle (1,241 caregivers + 2,295 disabled or new-parent adults + 3,295 students). Six-month hour checks for part-time workers stop 3,319 losses. Together they stop 10,150 losses (37.5% of 27,076 total losses, or 71.4% of the 14,219 avoidable pool).
• Scenario 3 Full Plan & Phone Upload: Adding wage follow-up for W-2 workers stops 2,228 losses. Clinic health checks and local service slots for non-working adults stop 1,841 losses. That brings the total to 14,219 (52.5%). Pairing with phone form upload adds +1,423 DHCS-scaled saves, reaching 15,642 of 27,076 (57.8%) on the DHCS scale (17,350 of 30,007 [57.8%] on the ACS scale).
How Funnel Decomposition Changes County Retention Budgeting
When a county sees a projected 36,000 to 41,000 drop in Medi-Cal plans, one top-line total gives no clear plan for staff. If leaders think those adults found job plans or chose not to work, the county will plan for smaller clinic panels. Meanwhile, ER teams will absorb thousands of newly uninsured patients who lost care over an unreturned form.
Splitting the renewal funnel by check stage and Census group shows that 88.5% of Santa Clara County's 120,239 expansion adults work at least 80 hours per month, hold a rule exemption, or work part-time hours. In our county model, 71.4% of all avoidable form losses (10,150 of 14,219 per cycle) hit exempt caregivers, disabled adults, students, and part-time workers. Moving outreach funds to clinic and school auto-flags, six-month hour checks, and one-page pay forms keeps people covered at a fraction of broad ad costs.
Data Sources, Model Inputs, Notes & Endnotes
(Numbered endnotes [1]–[5], state data sources & math rules)
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Case Study Focus: Program Impact · Flagship Case Study (Mode A Calibrated Funnel on Observed DHCS Enrollment Baseline)
Numbered Endnotes & Main Sources
- [1]California Health and Human Services (CHHS) Open Data Portal: Medi-Cal Certified Eligibles with Demographics by Month (
scc_dhcs_medical_enrollment.csv:1-134). Santa Clara County June 2025 Final count is 472,014 total, 255,601 adults 19–64, and 120,239 ACA expansion adults 19–64. That equals 2.5949% of 4,633,636 statewide. The June 2026 count is 105,436 (-12.31% pre-policy drop). The state Step 1–5 funnel comes from the California DHCS Implementation Plan for New Eligibility and Enrollment Changes under H.R. 1 (Webinar Deck, Feb 5, 2026, slides 13, 20–26, 34;dhcs_verification_funnel_scc.csv:1-11). Statewide, 1,842,155 (39.8%) clear at Steps 1–4. Santa Clara gets a 0.0% Step 2 jobless waiver share. That shifts +9,689 adults into Step 5 paper checks (82,126 vs. 72,437 flat-scaled) and yields 41,100 vs. 36,218 losses at a 50% Step 5 loss rate. - [2]U.S. Census Bureau ACS 2019–2023 5-Year PUMS (
extract_pums.py&scc_hr1_medicaid_risk_profiles.csv:1-46). We pull 97,933 person records across all 15 Santa Clara County PUMAs (08501–08515). The subset has n = 6,297 unweighted adults ages 19–64 on Medicaid/Medi-Cal (HINS4 = 1) without Medicare/SSI (HINS3 != 1, SSP = 0) at income ≤138% FPL (POVPIP ≤ 138). Using person weight PWGTP and 80 replicate weights (PWGTP1–PWGTP80) gives 133,998 ± 3,905 (rounded to 134,000) adults. Scaling to the 120,239 DHCS base shows 77.5% (93,233 DHCS-scaled) meet the ≥80 hr/mo rule in Group 1 (38.01%, 45,703 DHCS-scaled; 50,934 ± 2,423 ACS) or hold a rule exemption in Group 2 (39.53%, 47,530 DHCS-scaled; 52,971 ACS across Bucket B care <14 [30,074], Bucket C birth/disability [11,129], and Bucket D student [11,768]). Another 11.01% (13,226 DHCS-scaled; 14,752 ACS) work in Group 3 gig or part-time jobs (Buckets E [3,313], F [7,467], G [3,972]). Their status rests on a 1-month-in-6 lookback (88.5% = 106,459 summed across rounded groups, or 106,472 unrounded [0.885499 × 120,239]). That leaves 11.45% (13,767 DHCS-scaled; 15,341 ACS) in Group 4 without recorded work or a survey exemption. - [3]KFF Medicaid Unwinding & Work Requirement Research (Methodological reference: form disenrollment and check funnel benchmarks). CAPHE Mode A Renewal Funnel Model (
churn_reduction_model.py,churn_reduction_model_scc.csv:1-24,scc_hr1_synthesis.csv:8-15,INTERVENTION_DESIGN.md:155,239-241). For each group g, the Step 5 paper pool is M_g = N_g × p_step5. Here p_step5 is the share not cleared at Steps 1–4. Group 1 has 12,734 at Step 5. Group 2 has 18,870 (4,512 B + 6,120 C + 8,238 D). Group 3 has 10,275. Group 4 has 12,273. The total is M = 54,152. At the DHCS 50% Step 5 loss rate (L_g = 0.50 × M_g), six-month losses are 6,367 (13.9% of Group 1) + 9,435 (19.9% of Group 2) + 5,138 (38.8% of Group 3) + 6,136 (44.6% of Group 4) = 27,076 per cycle (30,174 on the 133,998 ACS scale). Multiplying L_g by avoidable shares r_g (0.35 in Group 1 = 2,228; 0.724 in Group 2 = 6,831 [1,241 B + 2,295 C + 3,295 D]; 0.646 in Group 3 = 3,319; 0.30 in Group 4 = 1,841) gives 14,219 of 27,076 (52.5%) avoidable losses per cycle (10,150 in Groups 2–3). Adding phone form upload raises that to 15,642 of 27,076 (57.8%) (+1,423 DHCS-scaled; 17,350 of 30,007 on the ACS scale). - [4]DHCS H.R. 1 Implementation Plan Webinar Deck (Feb 5, 2026)
- [5]ACS 2019–2023 PUMS
Mode Classification (Mode A Calibrated Funnel on Observed Enrollment Baseline): The county check funnel (36,218 to 41,100 per cycle under top-down scaling; 27,076 group losses and 14,219 or 52.5% avoidable in the 4-group model) is a Mode A model (dhcs_verification_funnel_scc.csv:1-11, churn_reduction_model_scc.csv:1-24). It is scaled to Santa Clara County's June 2025 DHCS base of 120,239 expansion adults (105,436 in June 2026; scc_dhcs_medical_enrollment.csv:1-134). The 133,998 ± 3,905 count (rounded to 134,000) is the ACS 2019–2023 5-Year PUMS weighted base (n = 6,297 records across PUMAs 08501–08515) used for group shares.
Primary Data Sources & Extract Specifications: Sources include the California Health and Human Services (CHHS) Open Data Portal (June 2025 Final to June 2026), the DHCS H.R. 1 Implementation Plan Webinar Deck (Feb 5, 2026), the U.S. Census Bureau ACS 2019–2023 5-Year PUMS (weights PWGTP and PWGTP1–PWGTP80), and KFF Medicaid Unwinding & Work Requirement Research.
Reconciliation of DHCS vs. ACS Denominators & Rounding: Table 1 lists both DHCS-scaled counts (N = 120,239: Group 1 = 45,703 [38.01%], Group 2 = 47,530 [39.53%], Group 3 = 13,226 [11.01%], Group 4 = 13,767 [11.45%]; sum of rounded groups 1–3 = 106,459, or 106,472 at unrounded 0.885499 × 120,239) and unscaled ACS PUMS weights (N = 133,998, rounded to 134,000: 50,934 + 52,971 + 14,752 + 15,341). County teams can match state plan dashboards directly to Census files.
Common Questions & Method Notes
- What share of Santa Clara County Medi-Cal expansion adults already work or qualify for an exemption?
- In Census data scaled to the 120,239 DHCS base, 77.5% of expansion adults already work at least 80 hours per month (38.0%) or hold a caregiver, disability, or student exemption (39.5%). Another 11.0% work in self-employed or part-time roles, reaching 88.5% in all. Only 11.5% (13,767 adults) have no logged work or survey exemption.
- Why does Santa Clara County face a higher per-capita disenrollment rate than the statewide DHCS average?
- The state DHCS check funnel exempts 373,389 adults living in high-unemployment or disaster counties before paper checks. Santa Clara County has a low jobless rate (~4.1%). As a result, 0% of its adults get a countywide jobless waiver. Projected six-month losses rise from 36,218 (flat state share) to 41,100.
- Which Medi-Cal groups experience the highest avoidable procedural churn?
- Exempt caregivers, disabled adults, and students face 6,831 avoidable form losses per cycle (72.4% avoidable). Self-employed and part-time workers follow with 3,319 avoidable form losses per cycle (64.6% avoidable).