February 22, 2023

Medicaid “Continuous Coverage” to End, Many Beneficiaries Unaware

Since the onset of the COVID-19 public health emergency (PHE), states have been operating their respective Medicaid programs under “continuous coverage” requirements. Such requirements blocked states from redetermining the eligibility of Medicaid recipients—also called “rebalancing”—to ensure that low-income Americans maintained stable health care coverage during the pandemic.

After more than three years and as serious COVID-19 cases have drastically declined, the Biden administration announced that the public health emergency will expire on May 11. And in Congress’ omnibus spending bill enacted at the end of 2022, it set the end date of the continuous coverage requirement as March 31, 2023. As such, beginning on April 1, states can begin disenrolling ineligible individuals from Medicaid.

Because many beneficiaries are unaware that this process is occurring, rebalancing is expected to put at risk the insurance coverage of millions of Medicaid beneficiaries. The Biden administration has predicted that 15 million people will lose coverage through Medicaid or the Children’s Health Insurance Program (CHIP). While some will lose coverage because they are no longer eligible, nearly half will be dropped for procedural reasons, such as failing to respond to requests for updated personal information. (The full report released by the U.S. Department of Health and Human Service’s Assistant Secretary for Planning and Evaluation can be viewed here.)

Academy members who see patients who get their health insurance through Medicaid, should be aware of these upcoming changes and assist patients accordingly.

What Medicaid beneficiaries can expect: Medicaid enrollees can expect to receive letters from their state’s Medicaid program requesting updated contact information, income verification, or other information needed to determine their eligibility. It is important that individuals ensure their contact information is up to date so that they do not miss these notifications. Since some states have already begun the process, these letters may have already come.

While all states are required to submit a “renewal distribution plan,” which tells the federal government how they plan to go about prioritizing Medicaid renewals, many states intend to take a full 12 months to complete the process. Some states will offer assistance in finding other insurance plans, including those in the Affordable Care Act marketplace (insurance exchange), but other states will leave that work to beneficiaries and navigators.

Impact on Certain Older Adults: A federal judge has issued a temporary injunction in the case Carr v. Becerra, which was brought against a Trump-era rule that had stripped Medicaid benefits from hundreds of thousands of low-income individuals protected by law against loss of Medicaid coverage during the COVID public health emergency. As a result of the ruling, states must promptly reinstate benefits to all individuals who lost them since March 18, 2020. Those individuals will also remain on Medicaid during the “unwinding” period described above. Readers can learn more about the litigation here.

Resources for providers:

• Centers for Medicare and Medicaid Services’ (CMS) Continuous Coverage Unwinding guidance: Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.
• CMS’ Temporary Special Enrollment Period (SEP) for Consumers Losing Medicaid or the Children’s Health Insurance Program (CHIP) Coverage Due to Unwinding of the Medicaid Continuous Enrollment Condition– Frequently Asked Questions (FAQ).
• Unwinding Medicaid Continuous Coverage: Checklist for Redeterminations Assists providers and advocates in determining whether their state’s Medicaid program has complied with redetermination requirements.
• Tribal health resources for assisters
• Graphic resources for providers and communications toolkit

Finally, to learn where your state is in this “unwinding” process or to compare it with other states across the nation, please consult this resource. Understanding how long your state plans to take for recertification, and better understanding which populations they are prioritizing and how, will help you better advocate for your patients. In addition to this enormous rebalancing of Medicaid rolls, there are many other issues at stake with the end of the PHE. You can view a list of those here.