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.
Protecting Coverage for Postpartum Individuals at the End of the Public Health Emergency
Patricia Boozang, Kinda Serafi, and Kaylee O’Connor, Manatt Health
For more than two years, states have maintained coverage of their Medicaid enrollees as a condition of receiving enhanced federal Medicaid funding under the Families First Coronavirus Response Act, resulting in considerable increases in coverage for all Americans, including pregnant and postpartum individuals. When the federal Medicaid continuous coverage requirement expires, states will redetermine eligibility for nearly all Medicaid enrollees, including roughly 1.7 million people enrolled in a Medicaid or CHIP pregnancy eligibility group. This issue brief reviews proactive strategies that states can deploy to support postpartum individuals in maintaining health coverage and access to care when the Medicaid continuous coverage guarantee ends and beyond.