On January 27, 2023, the Centers for Medicare & Medicaid Services released a State Health Official (SHO) letter, “Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.” The SHO letter is the second in a series of guidance related to section 5131 of the Consolidated Appropriations Act, 2023 (CAA), which established a fixed end date for the Medicaid continuous coverage requirement, a gradual phase-down for the enhanced federal match, and new guardrails for mitigating coverage loss for individuals who continue to be eligible. This expert perspective reviews the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter.
Assessment of Current Coverage Programs and Future Options
Manatt Health Solutions
This template, prepared by Manatt Health Solutions, is intended to assist states in evaluating the options with respect to transitioning certain Medicaid and state-funded populations and programs into a post-ACA coverage environment with Medicaid eligibility for non-disabled adults under age 65 (potentially) expanded to 133% of the FPL and tax credits and cost sharing reductions available to individuals between 133% and 400% of the FPL (or between 100% and 400% in a non-expansion state). The template suggests populations and programs that may be eligible to transition into the new adult Medicaid group or the Exchange, but each state will want to create a state-specific list of programs. With respect to each of the populations or programs eligible to transition, the template suggests nine factors for consideration, ranging from the difference in covered benefits and consumer cost-sharing to the impact on state financing and the administrative complexity of maintaining or eliminating the program. Finally, the template rolls up the considerations and lays out the possible decisions: maintain the program for some or all consumers; transition some or all consumers to the Medicaid new adult group; or, transition some or all consumers to the Exchange.
This template was rolled out by Manatt at the “Introduction to the State Health Reform Assistance Network” session at the 25th National Academy for State Health Policy Meeting on October 15, 2012. The slides from this presentation can be accessed here.