New CMS Guidance on Medicaid Continuous Coverage Unwinding Provisions in the Consolidated Appropriations Act, 2023
On Wednesday, February 8, State Health and Value Strategies will host a webinar during which experts from Manatt Health will review CMS’ recently released State Health Official (SHO) letter related to “unwinding” the Medicaid continuous coverage guarantee, based on provisions included in section 5131 of the Consolidated Appropriations Act, 2023 (CAA). The webinar will review the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter, and discuss key considerations for state policymakers.
Many consumers will find the relationship between Medicaid, the marketplace, and employer-sponsored insurance to be more complicated than ever in 2023 as the unwinding of the continuous coverage requirement begins. Much of the focus of Medicaid unwinding planning in states and the federal government has been on helping eligible people keep Medicaid coverage and steering the millions of people losing Medicaid eligibility toward the health insurance marketplace. Less attention has been devoted to the millions of people who are expected to be eligible for employer-sponsored insurance when their Medicaid coverage ends. This issue brief discusses how state Medicaid agencies, state-based marketplaces, labor departments, and employers can play critical roles in helping people understand and navigate their coverage options.
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.
Federal Declarations and Flexibilities Supporting Medicaid and CHIP COVID-19 Response Efforts Effective and End Dates
To help states respond to the ongoing COVID-19 pandemic, the White House, the U.S. Department of Health and Human Services, and the Centers for Medicare and Medicaid Services have invoked their emergency powers to authorize temporary flexibilities in Medicaid and the Children’s Health Insurance Program. Congress’s legislative relief packages have provided additional federal support for state Medicaid programs, subject to certain conditions. The timeframes for these emergency measures are summarized in the chart, including the effective dates and expiration timelines dictated by law or agency guidance. This SHVS product has been updated to reflect HHS’s January 11 notice renewing the federal Public Health Emergency and also includes a timeline of key Medicaid unwinding provisions included in the Consolidated Appropriations Act, 2023.
On Wednesday, January 11 State Health and Value Strategies hosted a webinar on the Consolidated Appropriations Act, 2023, an omnibus funding package that includes government appropriations through September 30, 2023 as well as a number of health policy provisions. Included in the package is a date certain for the expiration of the Medicaid continuous coverage requirement, a gradual phase down of the Families First Coronavirus Response Act enhanced federal match rate, and new guardrails to protect against inappropriate coverage loss and smooth coverage transitions. During the webinar, experts from Manatt Health and GMMB provided an overview of the unwinding provisions in the legislation, building on our recent expert perspective, Unwinding Provisions in the 2023 Consolidated Appropriations Act. Presenters discussed open questions and key considerations for state policymakers as they head into the final stretch of planning for the transition back to regular eligibility and enrollment operations.
State Health and Value Strategies hosted a working session for state officials responsible for operationalizing, refining, and overseeing eligibility and enrollment processes, including redeterminations/renewals and systems changes. The slide deck from the session provides an overview of ex parte processes and includes key ex parte resources in the appendix. The session provided state participants with the opportunity to pose questions to experts from Manatt Health regarding the issues they are facing as they work to improve their ex parte rates in preparation for the end of the continuous coverage requirements.
On Wednesday, November 2 State Health and Value Strategies hosted a webinar on the key considerations and requirements for state Medicaid/CHIP agencies at the end of the PHE. The webinar reviewed making permanent or terminating temporary COVID-19 flexibilities and returning to normal eligibility and enrollment processes. Presenters highlighted the intersection with our dynamic policy environment, including the recent CMS Proposed Rule on Medicaid and CHIP Eligibility, Enrollment, and Renewal.
Password protected resource page for members of the Coordinating the Continuous Coverage Unwinding affinity group.
Improving ex parte rates as part of the Medicaid renewal process is one of the most effective tools available to states to mitigate coverage loss for eligible individuals when the public health emergency (PHE) ends. There are tremendous benefits to enrollees and to states in maximizing eligibility redetermination through an ex parte process. As states develop their unwinding policies and operational plans in readiness for the end of the PHE, improving ex parte rates should be at the top of their priority list. This toolkit contains a table that can be used by a state to examine current ex parte processes and identify and deploy additional strategies that could increase their ex parte rates.
This toolkit highlights opportunities for states to leverage managed care plans to support unwinding the Medicaid continuous coverage requirement. Close collaboration between states and managed care plans will be essential to ensuring eligible individuals retain coverage in Medicaid/CHIP and easing transitions to the Marketplace. The toolkit features guidance released by CMS for states on working with managed care plans.