Resources for State Officials on COVID-19
Medicaid programs, health insurance Marketplaces, and insurance Commissioners have been working alongside Governors and public health leaders responding to the COVID-19 crisis. SHVS is bringing together toolkits, templates, state examples, and expert analysis.
As a condition of receiving enhanced federal funding under the Families First Coronavirus Response Act (FFCRA), states are prohibited from terminating individuals enrolled in Medicaid as of March 18, 2020, or determined eligible on or after that date. These continuous coverage requirements run through the end of the month of the public health emergency (PHE), which was recently extended to October 22, 2020. Absent a further extension of the PHE, states have three months to implement a plan for unwinding the FCCRA continuous coverage requirements which are otherwise set to terminate on October 31, 2020. States will also need to identify which newly obtained eligibility and enrollment flexibilities they would like to make permanent beyond the termination of the PHE–especially in the context of emerging information that suggests that the duration of COVID-19 pandemic may extend well into 2021.
States quickly mobilized to implement emergency federal authorities (e.g., Section 1135 waivers, 1915(c) Waiver Appendix K, emergency Section 1115 waivers) and state-level regulatory flexibilities to respond to the COVID-19 pandemic; now they must determine which flexibilities to scale back or sustain, taking into account fiscal implications. The interaction of the stimulus package dates, the Public Health Emergency, and the President’s National Emergency Declaration, among other factors, are complex, and states are actively grappling with decision making regarding which flexibilities they need and want to keep, and how. This Excel workbook is intended to serve as a tool for states as they strategize about reopening and plan for the next phase of the COVID-19 pandemic. Specifically, states can utilize this template to conduct both a primary analysis as they determine which flexibilities to unwind or maintain and a secondary analysis to plan for operational and implementation implications. The workbook has been updated to reflect the renewal of the Public Health Emergency as of July 23, 2020.
To help states respond to the ongoing coronavirus (COVID-19) pandemic, the White House, the U.S. Department of Health and Human Services (HHS), and the Centers for Medicare and Medicaid Services (CMS) have invoked their emergency powers to authorize temporary flexibilities in Medicaid and the Children’s Health Insurance Program (CHIP). Congress has passed legislation that provides additional federal support for state Medicaid programs, subject to certain conditions. The table summarizes the timeframes for these emergency measures, including the effective dates and expiration timelines dictated by law or agency guidance. The chart also includes current end dates, which are subject to change as federal and state officials take actions to renew or terminate particular authorities. This SHVS product has been updated to reflect HHS’s July 23 declaration renewing the federal Public Health Emergency, as well as CMS’s June 30 Key Dates for Termination of COVID-19 Flexibilities Table.