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.
The End of the Public Health Emergency Will Prompt Massive Transitions in Health Insurance Coverage: How State Insurance Regulators Can Prepare
Sabrina Corlette, Georgetown University’s Center on Health Insurance Reforms
Once the public health emergency ends, state Medicaid agencies will need to recommence Medicaid eligibility redeterminations and renewals. As a result, up to 16 million people are projected to lose their Medicaid coverage. While many of these will have gained access to employer-sponsored insurance, Medicare, or other sources of coverage, an estimated one-third will be eligible for subsidized coverage in the Affordable Care Act (ACA) Marketplaces. These shifts would represent the largest change in coverage status since implementation of the ACA.
Whether a state’s Medicaid agency moves swiftly or slowly to process eligibility redeterminations, the commercial insurance market–and particularly the ACA Marketplaces–could experience a significant growth in enrollment. This issue brief identifies several areas in which state departments of insurance (DOIs) may want to coordinate with other agencies or external stakeholders, issue new regulations or guidance, and establish means for minimizing gaps in coverage or access to services.