State Health and Value Strategies (SHVS) developed this resource page to serve as an accessible one-stop source of information for states in “unwinding” when the Medicaid continuous coverage requirement ends. The Families First Coronavirus Response Act (FFCRA) Medicaid “continuous coverage” requirement has allowed people to retain Medicaid coverage and get needed care during the pandemic. This resource is designed to support states planning for this major coverage event, including developing processes that prioritize coverage retention following the conclusion of the continuous coverage requirement. SHVS will update this page frequently with new resources as they become available.
State Health and Value Strategies (SHVS) developed this resource page to serve as an accessible one-stop source of information for states in “unwinding” when the Medicaid continuous coverage requirement ends. The Families First Coronavirus Response Act (FFCRA) Medicaid “continuous coverage” requirement has allowed people to retain Medicaid coverage and get needed care during the pandemic. This resource is designed to support states planning for this major coverage event, including developing processes that prioritize coverage retention following the conclusion of the continuous coverage requirement. SHVS will update this page frequently with new resources as they become available.
On May 17, 2022, the Department of Health Care Services (DHCS) released the Medi-Cal COVID-19 Public Health Emergency (PHE) Operational Unwinding Plan. The two primary purposes of this document are to: 1) describe DHCS’ approach to unwinding or making permanent temporarily flexibilities implemented across the Medi-Cal program during the PHE; and 2) describe DHCS’ approach to resuming normal Medi-Cal eligibility operations following the end of the PHE.
The Centers for Medicare & Medicaid Services (CMS) released a resource that reminds states of their obligation to continue to meet federal requirements related to eligibility and enrollment in Medicaid, the Children’s Health Insurance Program (CHIP), and the Basic Health Program (BHP) during the COVID-19 public health emergency unwinding period. This tool includes information for states on the requirements for eligibility renewals and redeterminations, application processing, fair hearings, coordination with the Marketplace, and other processes. Additionally, this resource highlights temporary options available to states during the unwinding period to facilitate eligibility and enrollment processing and retain coverage for eligible individuals.
As many as 16 million people are expected to lose Medicaid once the COVID-19 public health emergency and the Medicaid continuous coverage requirement end. One-third of these could be eligible for ACA marketplace plans. In a new post for the Commonwealth Fund’s To the Point blog, Sabrina Corlette and Maanasa Kona of the Georgetown Center on Health Insurance Reforms discuss strategies that marketplaces can deploy to help reduce the potential coverage loss and help consumers make a smooth transition
On April 22, 2022, CMS released a proposed rule that would create a Medicare special enrollment period (SEP) to be timed with the end of the Medicaid continuous coverage requirement. CMS is proposing the SEP for individuals enrolled in Medicaid when they initially qualify for Medicare who do not enroll in Medicare coverage when they turn 65, resulting in a coverage gap if they are then determined ineligible for Medicaid coverage following the end of the continuous coverage requirement. The proposed SEP would allow individuals to enroll after termination of Medicaid coverage following the end of the federal public health emergency (PHE) without being subject to a late enrollment penalty.
This toolkit highlights opportunities for states to leverage managed care plans to support unwinding the Medicaid continuous coverage requirement. Close collaboration between states and managed care plans will be essential to ensuring eligible individuals retain coverage in Medicaid/CHIP and easing transitions to the Marketplace. The toolkit, updated as of April 26, 2022, features guidance released by CMS for states on working with managed care plans.
To help states respond to the ongoing COVID-19 pandemic, the White House, the U.S. Department of Health and Human Services, and the Centers for Medicare and Medicaid Services have invoked their emergency powers to authorize temporary flexibilities in Medicaid and the Children’s Health Insurance Program. Congress’s legislative relief packages have provided additional federal support for state Medicaid programs, subject to certain conditions. The timeframes for these emergency measures are summarized in the chart, including the effective dates and expiration timelines dictated by law or agency guidance. This SHVS product has been updated to reflect HHS’s April 14 notice renewing the federal Public Health Emergency.
The Oklahoma Health Care Authority is preparing for the end of the Public Health Emergency (PHE) by asking all SoonerCare members to update their contact information and documentation.
Louisiana Medicaid has launched a phone campaign to encourage its members to update their contact information.
The New Hampshire Department of Health and Human Services created a webpage to host information on the unwinding of the federal Medicaid continuous coverage requirement, including sample member notices.
CA DHCS created a page on the unwinding of the federal Medicaid continuous coverage requirement, promoting a coordinated, phased communications plan to reach enrollees with messages across multiple channels using trusted messengers. The page includes a link to their Medi-Cal Continuous Coverage Toolkit.
The Centers for Medicare & Medicaid Services (CMS) released a new tool for states to utilize as they prepare to return to normal eligibility and enrollment operations after the COVID-19 public health emergency. The tool provides states with a summary of best & promising practices gleaned from discussions that CMS had with Medicaid agency leadership from each state, DC and three U.S. territories. The tool includes information on strategies states are implementing related to outreach, enrollee communications, renewals, updating enrollee contact information and addressing workforce issues to support their preparation for returning to normal eligibility and enrollment operations after the COVID-19 public health emergency.
The Centers for Medicare & Medicaid Services (CMS) released a new tool for states to utilize as they prepare to return to normal eligibility and enrollment operations after the COVID-19 public health emergency. The tool provides states with strategic approaches for processing Medicaid fair hearings as states resume normal eligibility and enrollment operations. Contained in the tool are steps a state may want to take to assess their fair hearing process and capacity, strategies to address anticipated fair hearing volume, and how to request authority from CMS to implement a mitigation strategy if needed.
New state reporting templates and guidance released by the Centers for Medicare & Medicaid Services (CMS) on March 22, 2022, build upon a State Health Official letter released on March 3. The resources specify both the data and the metrics that states will be required to submit to monitor enrollment and renewal efforts as they resume routine Medicaid and CHIP operations following the end of the COVID-19 PHE. This expert perspective summarizes the new reporting requirements and presents a set of considerations for states as they begin implementing new unwinding policies, procedures, and reporting.
Once the public health emergency ends, state Medicaid agencies will need to recommence Medicaid eligibility redeterminations and renewals. As a result, up to 16 million people are projected to lose their Medicaid coverage, and an estimated one-third of these individuals will be eligible for subsidized coverage in the Affordable Care Act (ACA) Marketplaces. Whether a state’s Medicaid agency moves swiftly or slowly to process eligibility redeterminations, the commercial insurance market–and particularly the ACA Marketplaces–could experience a significant growth in enrollment. This issue brief identifies several areas in which state departments of insurance (DOIs) may want to coordinate with other agencies or external stakeholders, issue new regulations or guidance, and establish means for minimizing gaps in coverage or access to services.
The Centers for Medicare & Medicaid Services (CMS) released additional templates and resources to support state reporting around enrollment and renewal efforts when the federal public health emergency (PHE) concludes. The resources include 1) a “Renewal Distribution Report” form in which states will be required to summarize their renewal plans, with a focus on mitigating inappropriate coverage loss during the unwinding period and 2) an “Unwinding Eligibility and Enrollment Data Reporting” Excel workbook and specifications document, which aims to support states in reporting on certain metrics around timely application processing, renewal initiation and completion, reason for termination, and fair hearings. CMS also previewed that states will eventually report on these metrics on a monthly basis.
A report from the Kaiser Family Foundation and Georgetown University Center for Children and Families presents a snapshot of actions states are taking to prepare for the lifting of the continuous enrollment requirement, as well as key state Medicaid enrollment and renewal procedures in place during the PHE.
A new Urban Institute issue brief, co-authored by researchers from Georgetown University, examines preparations for the end of the PHE in 11 states with SBMs. The brief identifies major challenges state officials are facing and best practices for keeping people in coverage that could be adopted by the federally facilitated Marketplace and SBMs.
A new Urban Institute report includes updated projections of Medicaid coverage and costs following the end of the public health emergency (PHE). The report builds upon a previous analysis on the rise in Medicaid enrollment at the start of the COVID-19 pandemic, mainly attributable to the continuous coverage requirement of the Families First Coronavirus Response Act. In their new brief, Urban projects Medicaid enrollment for the population under age 65 and federal and state Medicaid spending for 2022 and 2023, assuming the PHE is extended through the first, second, or third quarters of 2022. The authors find that the longer the PHE lasts, the greater the potential number of people losing Medicaid coverage over the 14 months after the PHE ends: 12.9 million if it expires after the first quarter of 2022, 14.4 million if it expires after the second quarter, and 15.8 million if it expires after the third quarter.
On March 3, the Centers for Medicare & Medicaid Services (CMS) released a State Health Official (SHO) letter, “Promoting Continuity of Coverage and Distributing Eligibility and Enrollment Workload in Medicaid, the Children’s Health Insurance Program (CHIP), and Basic Health Program (BHP) Upon Conclusion of the COVID-19 Public Health Emergency.” This expert perspective summarizes the highly anticipated guidance, which clarifies CMS expectations for state Medicaid and CHIP agencies as they prepare to process outstanding eligibility and enrollment actions when the federal Medicaid continuous coverage requirement ends.
CMS released a State Health Official letter outlining guidance to ensure states are well-prepared to initiate eligibility renewals for all individuals enrolled in Medicaid and CHIP within 12 months of the eventual end of the PHE and to complete renewals within 14 months. The new guidance provides reporting tools as well as an eligibility and enrollment tool.
The Tracking Medicaid Enrollment Growth During COVID-19 Databook provides a comprehensive, detailed look at Medicaid enrollment trends to-date. Using Medicaid enrollment data from over 40 states, the Databook provides a comprehensive, detailed look at Medicaid enrollment trends from the beginning of the COVID-19 pandemic through January 2021. The Databook provides enrollment detail by state across four eligibility categories: expansion adults, children (including those enrolled in CHIP), non-expansion adults, and aged, blind, and disabled individuals. It also compares enrollment trends across expansion and non-expansion states. While variations in states reporting mean that the enrollment numbers in this report are not necessarily comparable across states (and should not be summed across states), the data reported do allow states and others to track enrollment trends. As a companion to the Databook, Manatt Health authored an Overview that summarizes key findings from an analysis of the Databook.
Medicaid agencies are required to send written notices to enrollees as they begin their redetermination process after the continuous coverage requirement ends. This document contains template notices designed for use by state Medicaid agencies in their efforts to communicate with enrollees. State Medicaid agencies can customize these documents by editing them to input their state seal or agency logo and other state-specific information. These notices incorporate recommendations from the Centers for Medicare & Medicaid Services and reflect insights from qualitative testing with Medicaid enrollees during focus groups in February 2022.
When the Families First Coronavirus Response Act Medicaid “continuous coverage” requirement is discontinued states will restart eligibility redeterminations, and millions of Medicaid enrollees will be at risk of losing their coverage. A lack of publicly available data on Medicaid enrollment, renewal, and disenrollment makes it difficult to understand exactly who is losing Medicaid coverage and for what reasons. Publishing timely data in an easy-to-digest, visually appealing way would help improve the transparency, accountability, and equity of the Medicaid program. This expert perspective lays out a set of priority measures that states can incorporate over time into a data dashboard to track Medicaid enrollment following the end of the continuous coverage requirement. For a detailed discussion of the current status of Medicaid enrollment and retention data collection and best practices when developing a data dashboard to display this type of information, SHVS has published a companion issue brief.
As state Medicaid and Children’s Health Insurance Program (CHIP) agencies develop their strategies for unwinding the federal Medicaid continuous coverage requirement under the Families First Coronavirus Response Act, many are looking to text messaging as a mechanism for outreach to their Medicaid and CHIP enrollees and communicating important information. This expert perspective describes states’ authority to send text messages and requirements for obtaining consent. The expert perspective also contains sample consent language to include in the Medicaid/CHIP application as well as template text messages.
The Families First Coronavirus Response Act (FFCRA) Medicaid “continuous coverage” requirement has allowed people to retain Medicaid coverage and get needed care during the COVID-19 pandemic. When continuous enrollment is discontinued, states will restart eligibility redeterminations, and millions of Medicaid enrollees will be at risk of losing their coverage. The current lack of publicly available and timely Medicaid enrollment, renewal, and disenrollment data will make it difficult to understand exactly who is losing coverage and for what reasons. One effective way to monitor this type of information is through the use of Medicaid enrollment and retention dashboards. This issue brief examines the current status of data collection to assess Medicaid enrollment and retention, summarizes potential forthcoming reporting requirements, and describes some of the best practices states should consider when developing a data dashboard to display this type of information. The issue brief lays out a phased set of priority measures and provides a model enrollment and retention dashboard template.
To help states respond to the ongoing COVID-19 pandemic, the White House, the U.S. Department of Health and Human Services, and the Centers for Medicare and Medicaid Services have invoked their emergency powers to authorize temporary flexibilities in Medicaid and the Children’s Health Insurance Program. Congress’s legislative relief packages have provided additional federal support for state Medicaid programs, subject to certain conditions. The timeframes for these emergency measures are summarized in the chart, including the effective dates and expiration timelines dictated by law or agency guidance. This SHVS product has been updated to reflect HHS’s January 14 notice renewing the federal Public Health Emergency.
On November 24, CMS released a “punch list” of strategies states and the US territories can adopt to maintain coverage of eligible individuals as they return to normal operations after the end of the public health emergency. The strategies are organized around seven topics areas: (1) strengthening renewal processes; (2) updating mailing addresses; (3) improving consumer outreach, communication, and assistance; (4) promoting seamless coverage transitions; (5) improving coverage retention; (6) addressing strains on the eligibility and enrollment workforce; and (7) enhancing oversight of eligibility and enrollment operations. In this resource, CMS also flagged strategies they expect to have the biggest impact on mitigating coverage losses.
On Wednesday, November 10 State Health and Value Strategies hosted a webinar that provided an overview of strategies for states seeking to ensure that eligible enrollees are able to keep or transition to new affordable health coverage when the Medicaid continuous coverage requirement ends. States will be resuming eligibility and enrollment activities for all enrollees in Medicaid and the Children’s Health Insurance Program (CHIP), and as part of their planning, states have an opportunity to retain coverage gains experienced over the pandemic period by taking steps to ensure that eligible enrollees are able to keep Medicaid/CHIP coverage, and those who are eligible for subsidized Marketplace coverage are transitioned and enrolled. Experts from Manatt Health and McKinsey & Company discussed how states can prepare now by deploying strategies to update enrollee contact information, and make other eligibility and enrollment technology changes to better serve their residents.
Following the expiration of the Public Health Emergency (PHE), states will resume normal eligibility and enrollment activities for all enrollees in Medicaid and the Children’s Health Insurance Program (CHIP). The volume of expected redetermination activity at the end of the PHE is unprecedented. This issue brief reviews state Medicaid/CHIP agency data and information technology (IT) system “table stakes”—strategies that will have the highest impact for states seeking to ensure that eligible enrollees are able to keep or transition to new affordable health coverage when the PHE continuous coverage requirements end. If adopted, these strategies will also enable states to dramatically improve Medicaid/CHIP enrollment and coverage retention in the longer-term for people eligible for government subsidized health coverage.
At the end of the public health emergency (PHE), people currently enrolled in Medicaid and the Children’s Health Insurance Program are at risk of losing their coverage unless state Medicaid/CHIP agencies take steps to update enrollee mailing addresses and other contact information. This expert perspective examines the information technology system, policy, and operational strategies states can consider to update key enrollee contact information to ensure eligible enrollees are able to keep or transition to new affordable health coverage at the end of the PHE.
To help states respond to the ongoing coronavirus (COVID-19) pandemic, the White House, the U.S. Department of Health and Human Services, and the Centers for Medicare and Medicaid Services have invoked their emergency powers to authorize temporary flexibilities in Medicaid and the Children’s Health Insurance Program. Congress’s legislative relief packages have provided additional federal support for state Medicaid programs, subject to certain conditions. The timeframes for these emergency measures are summarized in the chart, 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.
On Wednesday, April 29 State Health and Value Strategies hosted a webinar, State Strategies to Support Medicaid/CHIP Eligibility and Enrollment in Response to COVID-19. Many states are experiencing an increase in the volume of Medicaid applications due to the COVID-19 pandemic and the resulting economic crisis. It is important for states to understand the policy and operational strategies they can use to ensure that people who are eligible for the Medicaid program can apply, enroll and start receiving benefits as quickly as possible. During the webinar experts from Manatt Health reviewed strategies states can use to manage and process an increased number of Medicaid applications, and the federal authorities that permit states to do so. Communications experts from GMMB reviewed strategies for messaging to new and existing enrollees. As a companion to this webinar, SHVS has also published a Medicaid COVID-19 Messaging toolkit.
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.
On Thursday, January 21 State Health and Value Strategies hosted a webinar on the long-awaited guidance to state Medicaid and CHIP agencies on resuming normal operations following the end of the COVID-19 public health emergency. During the webinar experts from Manatt Health discussed the sub-regulatory guidance and the implications for states, in light of the recent public health emergency renewal by Secretary Azar. The webinar reviewed the expectations laid out in the guidance related to timelines, consumer communications, and fair hearing processes for redetermining Medicaid eligibility for those who have had their coverage continuously maintained as a condition of receiving the temporary 6.2 percent FMAP increase under the Families First Coronavirus Response Act. Additionally, presenters discussed the expected processes and timelines for terminating, or making permanent where allowable, temporary federal flexibilities that were obtained.
On January 6, 2021, CMS released an updated FAQ document that incorporates all eight sets of COVID-19 FAQs into one, comprehensive FAQ document.
CMS Expanding Coverage Under Medicaid and CHIP: Materials developed by the Expanding Coverage MAC Learning Collaborative for states.
Following unprecedented Medicaid enrollment during the public health emergency, analysis projects that 15 million people could lose Medicaid coverage when the emergency declaration ends.
With support from the Robert Wood Johnson Foundation, Benefits Data Trust (BDT) has developed this “Medicaid Churn Toolkit” to guide Medicaid agencies and their partners in the design and implementation of efforts to reduce churn as they plan for the resumption of normal eligibility and enrollment actions (including renewals, redeterminations, and post-enrollment verifications) and beyond.
On December 22, 2020, the Centers for Medicare and Medicaid Services released long-awaited guidance to state Medicaid and CHIP agencies on resuming normal operations following the end of the COVID-19 public health emergency. This issue brief provides a high-level summary of the CMS guidance related to: (1) conducting redeterminations for Medicaid enrollees who were continuously enrolled; (2) terminating, or extending where appropriate, temporary flexibilities; and (3) developing a consumer and provider communication strategy.