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.
Helping Consumers Navigate Medicaid, the Marketplace, and Employer Coverage
Tara Straw, Manatt Health and Julie Bataille, GMMB
The 2023 Consolidated Appropriations Act separated the Medicaid continuous coverage provision from the COVID-19 public health emergency and provided a fixed end date of March 31, 2023 for the Medicaid continuous coverage guarantee. Many consumers will find the relationship between Medicaid, the marketplace, and employer-sponsored insurance (ESI) to be more complicated than ever in 2023 as the unwinding of the continuous coverage requirement begins. Roughly 18 million people are expected to lose Medicaid coverage of which 9.5 million are expected to enroll in ESI. Much of the focus of Medicaid unwinding planning in states and the federal government has been on helping eligible people keep Medicaid coverage and steering the millions of people losing Medicaid eligibility toward the health insurance marketplace. Less attention has been devoted to the millions of people who are expected to be eligible for ESI when their Medicaid coverage ends. This issue brief discusses how state Medicaid agencies, state-based marketplaces, labor departments, and employers can play critical roles in helping people understand and navigate their coverage options.
A companion issue brief, Unwinding the Medicaid Continuous Coverage Requirement—Transitioning to Employer-Sponsored Coverage discusses the proportion of individuals with an offer of employer-sponsored coverage by income and state, and the proportion of those offers that are considered affordable based on premium cost.
To support communications efforts during the unwinding, SHVS has also produced sample messaging for state departments of labor to share with the employer community which explains the unwinding and coverage options for employees.