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.
The Center for Medicaid and CHIP Services (CMCS) explained the transition to “Account Transfer 2.0” (AT 2.0) in a CMCS Informational Bulletin (CIB) released on October 10, 2024. The CIB indicates significant federal investment in improving the process of transferring consumer application information between state Medicaid and CHIP agencies and the Marketplace in the states using the federal platform. This expert perspective reviews the CIB and highlights opportunities for states to improve account transfer data under the CIB.
On September 9, the Centers for Medicare & Medicaid Services (CMS) released a new collection of federal Medicaid and CHIP reporting templates designed to assist states in monitoring Mental Health Parity and Addiction Equity Act (MHPAEA) compliance in Medicaid and CHIP. Informal public comment is requested by December 2, 2024. This expert perspective reviews the reporting templates to highlight considerations for states and support the formulation of comment submissions.
On April 2, 2024, the Centers for Medicare & Medicaid Services offered a new option for states to update their essential health benefits (EHB) benchmark plan to require coverage of routine adult dental benefits. While there are multiple drivers of inequities in oral health, a primary barrier to accessing dental services is the cost of care, a barrier that can be reduced with dental insurance. This expert perspective provides an overview of the newly available flexibility and discusses considerations for states weighing whether to add a requirement that plans subject to EHB cover routine adult dental care.