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.
Coverage Alternatives for Low and Modest Income Consumers
Manatt Health Solutions
To ensure a seamless system of coverage, the Affordable Care Act (ACA) requires a single streamlined application for all Insurance Affordability Programs (IAPs) and a coordinated process for IAP eligibility and enrollment. States looking beyond the eligibility and enrollment process can utilize this chart to explore different mechanisms to address the cost-sharing cliff in the Exchange and also to promote continuity of coverage and care as consumers transition across IAPs. The following chart, developed by Manatt Health Solutions, provides a side-by-side analysis of coverage alternatives under state and federal consideration including: the Basic Health Program (BHP); the Bridge Plan; Qualified Health Plan (QHP) Premium and Cost-Sharing Support; maintaining existing Medicaid expansions above 133 percent FPL; and Premium Assistance. These options are compared against subsidized QHP coverage available under the ACA.