(Photo Courtesy: Urban Health Plan in Bronx, NY)
At the end of 2022, the federal spending package by Congress included a provision that uncoupled the Medicaid continuous enrollment with the COVID-19 public health emergency (PHE). Medicaid continuous enrollment was a requirement put in place during the pandemic to prevent Medicaid beneficiaries from losing coverage during the COVID-19 pandemic. This was a protection to help ensure people had access to care during the uncertainty of COVID-19. As of September 2022, over 90 million people across the country were enrolled in Medicaid and CHIP. For comparison, there was 70.9 million individuals enrolled in March 2020. This uncoupling now allows State Medicaid Agencies to restart their eligibility and enrollment operations for all Medicaid and CHIP beneficiaries.
Health centers serve over 30 million patients, including one in five Medicaid beneficiaries and one in three people living in poverty. It’s estimated that approximately 15 million people may lose coverage during the next year through the unwinding. The pace and extent of disenrollment will vary by state. While federal and state agencies have been planning for this event, beneficiaries may still encounter confusion regarding their health care coverage. Health centers will play a pivotal role assisting states with redeterminations for Medicaid beneficiaries. During this period, it will be critical to protect patients from losing health insurance for which they are qualified via Medicaid, CHIP, employer-sponsored or marketplace coverage to preserve their continuity of care and services.
Use our “Medicaid PHE Unwinding” social media graphics to notify patients about what they need to do to avoid losing coverage. View graphics.
The Centers for Medicare and Medicaid Services (CMS) has released guidance to states as they begin operations to return to normal. Health centers and patients should be aware of the following key deadlines and actions:
States will have 12 months to initiate redeterminations aka “the unwinding”
Over the last two years the federal government has released communication tool kits, resources to support coordination to the insurance marketplace, and general unwinding guidance for redeterminations. Available guidance can be found on Medicaid.gov. States will have up to 12 months to initiate and 14 months to complete a renewal for all individuals in Medicaid, CHIP, and the Basic Health Program. The year-end spending package does not change this timeline.
The March 31, 2023, statutory end date of the continuous enrollment condition means that states could begin their 12-month unwinding period and initiate the first Medicaid renewals as early as February 1, 2023.
CMS guidance previously explained the following general timeline that states:
- Should begin renewals in the month before, of, or after the month in which the continuous enrollment condition ends. This may be February, March, or April 2023.
- Must initiate renewals for all individuals enrolled as of the last day of the continuous enrollment condition within 12 months – This date is March 31, 2024.
- Must complete renewals for individuals enrolled as of the last day of the continuous enrollment condition within 14 months – This date is May 31, 2024.
Each state’s Medicaid agency contact information can be found here.
Medicaid disenrollment begins April 1
Beginning April 1, 2023, states will be able to terminate Medicaid enrollment for people who are no longer eligible. The recent 90-day extension of the PHE has no impact to this April 1st date. Health center patients may lose Medicaid coverage due to changes in income, ability to receive health insurance through a different source or other family circumstances. However, some patients may lose Medicaid coverage despite still being eligible for Medicaid. This may occur because of administrative barriers (i.e., old contact information or missing deadlines to submit information to determine eligibility). CMS also released updated guidance on utilizing managed care organizations to assist with the redetermination process. This approach may help protect patients from losing coverage due to administrative reasons.
While a state may begin renewals in February, states that have accepted the temporary FMAP increase will not be terminated until the first day of the month, April 1, 2023, when the continuous enrollment condition ends.
Guardrails to protect patients
The bill also included language to provide government oversight during the unwinding process to help protect beneficiaries. Additional guidance from CMS is forthcoming on these requirements.
It is important to note that states beginning renewals in February must submit renewal redistribution plans and system readiness artifacts by February 1. States that plan to start renewals after February have until February 15 to submit these plans.
NACHC has resources to support health centers in preventing patients from losing Medicaid coverage
NACHC is looking to partner with and uplift the incredible work that health center leaders are doing to protect Medicaid and CHIP patients. NACHC created the following resources to engage and support health centers:
- An online forum with all essential information and guidance in one place. Also allows health center staff to learn about best practices and engage with peers. Complete this form to request access.
- NACHC will stand up a workgroup with PCA staff, health center leaders, navigators and assistors to collaborate and share real-time information relating to developments on the ground. Applications are due Friday, February 3.
For more information, please contact Erin Prendergast, Deputy Director of Federal Policy, firstname.lastname@example.org.