Since the start of the COVID-19 pandemic, the number of people enrolled in Medicaid has increased by nearly 20%, with close to 85 million people currently enrolled in Medicaid and CHIP.
However, approximately 16 million people – including nearly 7 million children – are expected to lose coverage once the various coverage protections, established by Congress ultimately expire along with the federal public health emergency (PHE) designation.
In a new development, there is reason to believe that the PHE may be extended. In late 2021, the US Department of Health and Human Services stated it would provide states with 60 days’ notice prior to termination of the federal PHE. The 60-day window of notice passed earlier this week with indications that another extension is expected [see CNN interview with Biden Administration officials on continuing PHE]. Should HHS officially announce another extension, the PHE will have a new expected end date in mid-October 2022. The time period for states to process redeterminations remains the same. States are prohibited from disenrolling Medicaid beneficiaries during the PHE.
NACHC and the broader Medicaid community are closely monitoring and assessing ways to support patients. There is a lot at stake: nearly half of health center patients are enrolled in Medicaid, and as a result of the pandemic, continuous coverage, and other policy flexibilities, 90% of health centers have been able to treat more patients. States will have to redetermine eligibility for Medicaid, and it is critical that health centers be at the forefront of working with enrollees who are at risk of losing coverage.
To support states to prepare for the unwinding, the Centers for Medicare and Medicaid Services (CMS) issued new guidance last month that advises states they will ultimately have 14 months to complete their redetermination and renewal process from the time they choose to “unwind.” States can begin the redetermination process up to two months prior to the declared end of the PHE; however, they must maintain continuous coverage of all beneficiaries during the early start period. States are also required to develop “Unwinding Operational Plans” that outline strategies for the redetermination process.
Some state officials have expressed concerns about the timeline and the resulting “churn” of beneficiaries – people who will be disenrolled for a period of time before regaining coverage either through Medicaid, Affordable Care Act marketplace coverage or another pathway. Outreach is a major challenge because many beneficiaries have moved during the pandemic due to housing instability. Without updated contact information, state Medicaid departments face the difficulty of locating beneficiaries and sending notices to enrollees about their eligibility status. CMS also released a communications toolkit with strategies for enrollees and state agencies to engage in for more effective outreach.
Health centers play a vital role in assisting communities with Medicaid enrollment through their outreach and enrollment workers. In 2020, health centers employed almost 7,000 staff who provided 3.6 million enrollment education sessions to patients. For beneficiaries who are eligible for coverage through Affordable Care Act exchanges, health centers can begin working with patients to start the transition to coverage other than Medicaid. As states prepare for the termination of the PHE and resulting Medicaid redeterminations, it is imperative that health centers, PCAs, and HCCNs work closely with state Medicaid departments and other stakeholders to address the challenges. NACHC recommends that health centers develop campaigns to inform patients of the upcoming Medicaid “cliff” and work closely with their state’s Medicaid department and managed care organizations on their Unwinding Operational Plans.
NACHC recently hosted a briefing on the Medicaid “cliff” and state activities on March 28, 2022 and will continue to monitor the situation as it evolves. Please refer to the resources below for additional information:
- NACHC Memo on Unwinding CMS Guidance
- Medicaid Unwinding webpage
- CMS Slides for Health Plans
- Eligibility and Enrollment Planning Tool
- CMS State Renewal Report
- Perspectives on Guidance from CBPP
Mallika Yadwad is a Program Associate with NACHC’s Federal & State Policy team.
Editor’s note: This story was updated on May 19th, 2022 to reflect new developments.