Unwinding the Medicaid Continuous Coverage Requirement—Transitioning to Employer-Sponsored Coverage
Elizabeth Lukanen and Robert Hest, SHADAC
The 2023 Consolidated Appropriations Act separated the Medicaid continuous coverage provision from the COVID-19 public health emergency and provided a fixed end date of March 31, 2023 for the Medicaid continuous coverage guarantee. When the unwinding of the Medicaid continuous coverage requirement begins, states will restart eligibility redeterminations, and millions of Medicaid enrollees will be at risk of losing their coverage. While much attention has been paid to how states can approach the unwinding of the continuous coverage requirement to prioritize the retention of Medicaid coverage and transitions to marketplace coverage, less attention has been paid to the role of employer-sponsored insurance. To get a sense for the size of the group that might have employer-sponsored coverage as an option, this issue brief discusses the proportion of individuals with an offer of employer-sponsored coverage by income and state, and the proportion of those offers that are considered affordable based on premium cost. The issue brief also discusses the importance of a Medicaid disenrollment survey to monitor the coverage transitions associated with the unwinding.
To support communications efforts during the unwinding, SHVS has also produced sample messaging for state departments of labor to share with the employer community which explains the unwinding and coverage options for employees.
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.
On January 26, 2023, the Centers for Medicare & Medicaid Services approved California’s request to amend the California Advancing and Innovating Medi-Cal Section 1115 demonstration. This expert perspective describes the amendment, a centerpiece of which is approval for California Medicaid to provide a targeted set of Medicaid services to youth and adults in state prisons, county jails, and youth correctional facilities for up to 90 days prior to release. By providing re-entry services to Medicaid-enrolled individuals who are incarcerated, California aims to build a bridge to community-based care for justice-involved enrollees, offering them services to stabilize their physical and behavioral health conditions and establishing, prior to release, a re-entry plan for their community-based care.
On January 23, 2023, the Federal Communications Commission issued an important ruling that provides states with new flexibility to support enrollee outreach and communication efforts as part of their processes to unwind the Medicaid continuous coverage requirement. The ruling permits state agencies and their partners to send text messages and make phone calls to individuals about enrollment-related issues not only for Medicaid but for other state-run health insurance programs, including marketplace coverage. This expert perspective reviews the ruling and implications for states.
