The unwinding related section 1902(e)(14) strategies newly available to Medicaid and CHIP agencies can provide significant relief to states facing pending eligibility and enrollment actions and processing delays, workforce and systems limitations, and other operational challenges. Ensuring eligible individuals do not lose coverage for procedural or administrative reasons and supporting those who are ineligible for Medicaid/CHIP transition to Marketplace coverage will be paramount for all states as they begin to resume normal operations when the federal public health emergency (PHE) ends. This expert perspective outlines the time-limited targeted enrollment flexibilities that CMS has availed to states through section 1902(e)(14) waiver authority and discusses considerations beyond the strategies described in federal guidance and supplemental resources.

Providing a retroactive coverage option in the Marketplace is one innovative strategy for eliminating coverage gaps between Medicaid and Marketplace coverage for people eligible to make that transition at the end of the public health emergency. Pennsylvania’s state-based Marketplace, Pennie, is considering an optional retroactive coverage policy. This expert perspective describes the retroactive coverage policy innovation and its benefits, and offers strategies for states to consider in their implementation that will maximize coverage continuity, minimize adverse selection, and address potential operational challenges.

State updates as of June 10, 2022.