By Cathy Zhang
The COVID-19 Public Health Emergency (PHE) expires at the end of this week, with Department of Health and Human Services (HHS) Secretary Xavier Becerra expected to renew the PHE once more to extend through mid-July.
When the PHE ultimately expires, this will also trigger the end of the Medicaid continuous enrollment requirement, under which states must provide continuous Medicaid coverage for enrollees through the end of the last month of the PHE in order to receive enhanced federal funding. This policy improves coverage and helps reduce churn, which is associated with poor health outcomes.
After the PHE, states can facilitate smooth transitions for those no longer eligible for Medicaid by taking advantage of the full 12- to 14- month period that the Centers for Medicare & Medicaid Services (CMS) has established for redetermining eligibility.
In August 2021, CMS released guidance giving states up to 12 months following the end of the PHE to redetermine whether Medicaid enrollees were still eligible and renew coverage. Last month, CMS released new guidance specifying that states must initiate redeterminations and renewals within 12 months of the PHE ending, but have up to 14 months to complete them. The agency is encouraging states to spread its renewals over the course of the full 12-month unwinding period, processing no more than 1/9th of their caseloads in a month, in order to reduce the risk of inappropriate terminations.
What States Are Doing Now
Two weeks after CMS issued its March 2022 guidance, the Kaiser Family Foundation released its annual survey of state Medicaid and Children’s Health Insurance Program (CHIP). Data for the report was collected in January, before the issuance of the latest guidance, and reflects states’ plans at the time for approaching redetermination and actions taken in anticipation of the unwinding.
While states cannot disenroll people from Medicaid during the PHE, they can take proactive steps to renew coverage for current enrollees. Through a process called ex parte renewal, states can look at existing data on enrollees to determine if they are still eligible for Medicaid, in which case the state will renew their coverage without the enrollee taking any additional steps. States are required by law to attempt an ex parte renewal before requesting any forms or documentation from an enrollee.
The annual survey found that 42 states were already processing ex parte renewals in January. The March CMS guidance also encourages states to expand their data sources for conducting ex parte renewals, which would make it possible to successfully conduct more renewals without requiring further action from enrollees.
The annual survey also found that 46 states have plans to update enrollees’ addresses before the end of the PHE. Doing so can ensure that more enrollees actually receive any renewal forms they may need to fill out, thereby improving continuity. To further improve the rate of contact for enrollees, 35 states plan follow-up on returned mail via telephone, email, and text before terminating coverage after the PHE.
Continuity of Coverage
Based on data from 20 states, the annual survey found that an estimated 13% of current enrollees will lose their Medicaid coverage at the end of the continuous enrollment period.
In an effort to reduce loss of coverage, 41 states have indicated they will follow up with enrollees when individual action is required to maintain coverage. States are not, however, required to follow up with enrollees before terminating coverage once a renewal request has been sent out.
Not all state plans are geared towards maximizing coverage, however. In January, 11 states had plans to target individuals who appear to be no longer eligible first, and 15 states indicated they would use data to identify and target enrollees who may no longer be eligible for priority action after the PHE.
Data for Future Policymaking
Along with guidance for the timeline of conducting redeterminations, the new CMS guidance requires states to submit monthly data on their processing of applications and renewals for at least 14 months. In addition to ensuring compliance with the timeline requirements for the unwinding period, this may empower policymakers to quantify the effects of continuous enrollment, as well as different approaches to renewals, to make long-term strategies for improving coverage.