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.
New State Guidance on Resuming Normal Operations After the Public Health Emergency
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.
As a companion to the webinar, we have also published an issue brief CMS Guidance to States on Resuming Public Health Program Operations Post the COVID-19 Public Health Emergency that provides a high-level summary of the guidance.