New CMS Guidance on Medicaid Continuous Coverage Unwinding Provisions in the Consolidated Appropriations Act, 2023
Manatt Health
On Wednesday, February 8, State Health and Value Strategies hosted a webinar during which experts from Manatt Health reviewed CMS’ recently released State Health Official (SHO) letter related to “unwinding” the Medicaid continuous coverage guarantee, based on provisions included in section 5131 of the Consolidated Appropriations Act, 2023 (CAA). Building on existing CMS guidance, the new SHO letter details the requirements that states must comply with in order to receive the enhanced federal medical assistance percentage; clarifies expectations for states to comply with the Medicaid, CHIP, and marketplace reporting elements required by the CAA; and reviews implications of the CAA on select COVID-19 public health emergency-related flexibilities and authorities.
The webinar reviewed the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter, and discussed key considerations for state policymakers. As a reminder, SHVS has created a single-stop resource page to support states as they plan for unwinding. For more information on the CAA and unwinding, see the first webinar on the unwinding provisions in the CAA, Omnibus Unwinding Provisions and Implications for States.
UPDATE: During the discussion portion of the webinar (timestamp 40:28 to 41:30 in the recording), a question was posed to presenters about whether states are required to make available all modalities to return the renewal form for both Modified Adjusted Gross Income (MAGI) and non-MAGI populations. Upon further research, we would like to clarify that states are indeed required to make available all modalities to return the renewal form for both MAGI and non-MAGI populations. This is an existing federal regulatory requirement that was restated and clarified in the August 2022 CMS eligibility and enrollment proposed rule, “Streamlining the Medicaid, Children’s Health Insurance Program, and Basic Health Program Application, Eligibility Determination, Enrollment, and Renewal Processes.”
To maximize efforts to maintain coverage, state Medicaid agencies and Marketplaces can now leverage digital channels as part of their overall outreach and communications efforts. Rapidly evolving changes in consumer media consumption habits as well as shifts in digital channels, and the ability to leverage data sources, enables granular audience targeting and efficient use of resources. These can be incorporated into an overall integrated outreach and education campaign to maximize renewals and coverage retention.
Individual-level data on race and ethnicity collected within the Medicaid program and in other state agencies is greatly influenced by federal guidance. This expert perspective summarizes the proposed revisions to the federal standards for collecting race and ethnicity that are currently out for comment, and provides considerations for states interested in submitting comments.
The unwinding of the Medicaid continuous coverage requirement represents the largest nationwide coverage transition since the Affordable Care Act, with significant health equity implications. Given the intense focus on coverage transitions during the unwinding, some states have initiated plans to publish a data dashboard to monitor progress. To date, three states—Iowa, Minnesota and Utah—have a public data dashboard. SHADAC will update this expert perspective as additional dashboards go live.
