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.
Following the November release of guidance to support states’ efforts to verify eligibility and conduct renewals in compliance with federal Medicaid and CHIP requirements, the Centers for Medicare & Medicaid Services issued on December 20 two additional Center for Medicaid and CHIP Services Informational Bulletins (CIBs). This expert perspective summarizes the requirements outlined in the CIBs.
On December 19, the Centers for Medicare and Medicaid Services released State Health Official (SHO) letter 24-006, “Provision of Medicaid and CHIP Services to Incarcerated Youth – FAQs,” which provides several clarifications for states on compliance expectations for implementing section 5121 of the Consolidated Appropriations Act of 2023. This expert perspective describes key clarifications addressed in the SHO letter.