Over 91 million individuals are now enrolled in Medicaid and CHIP. That’s an astonishing 29.5% increase in enrollment since the beginning of the COVID-19 pandemic. Thanks to the continuous coverage requirement, states could not disenroll anyone in Medicaid until the end of the COVID-19 Public Health Emergency (PHE) — until now.

In past blogs we’ve talked about the Medicaid coverage losses that could result at the end of the COVID-19 PHE. While coverage losses are still very much a threat, the recently enacted Consolidated Appropriations Act, 2023 (CAA)  de-coupled the Medicaid continuous coverage requirement from the end of the PHE — which will stay in place until May 11, 2023.

What Does this Mean?

Beginning April 1, 2023, states may begin to disenroll individuals and families who are no longer eligible for Medicaid (also referred to as Medicaid “unwinding”).

Before states terminate anyone’s Medicaid enrollment, they must first conduct a renewal. If a state’s Medicaid office requires additional information to determine eligibility (or “redetermination” as it’s often called), they will reach out to the enrollee to provide updated paperwork. The Medicaid unwinding period, thereby initiating Medicaid renewals, could begin as early as February 1, given the guidance the Centers for Medicare and Medicaid Services (CMS) issued following the CAA’s passage.

CMS has also issued important guidance for states to refer to when conducting Medicaid renewals:

• The agency issued guidance in March 2022 on how states need to prepare and think about conducting redeterminations and disenrolling those who are no longer eligible for Medicaid.
• CMS has also issued new guidance reminding states of proper renewal requirements, all the methods of updating enrollee contact information and using multiple ways (mail, telephone, text, online) of reaching people before terminating their enrollment.

What Happens if Someone is No Longer Eligible for Medicaid?

For people who are no longer eligible for Medicaid, marketplace coverage may be an option. Outside of the yearly marketplace open enrollment period, a loss of coverage, like Medicaid, normally triggers a 60-day special enrollment period (SEP) for someone to apply for marketplace coverage.

CMS announced a new SEP for marketplace coverage for those who lose Medicaid or CHIP during the Medicaid unwinding in states that rely on Healthcare.gov. This SEP will run between March 31, 2023, and July 31, 2024. This longer SEP means that individuals won’t have to worry about reaching out to the marketplace within 60 days of losing Medicaid.

What are States Doing?

State Medicaid agencies are hard at work planning and preparing for the unwinding — or returning to normal operations, which includes conducting redeterminations and disenrolling individuals from Medicaid. All states are working on the timeline for when this process will begin.

For example, we know from California’s updated plan that the state will begin renewals in April. California also launched a public information and outreach media campaign and webpage around the upcoming Medi-Cal renewals.

We also have a glimpse into Florida’s planning efforts, when the state released an unwinding plan that begins initiating renewals in March. The majority of states have plans publicly available and many others have released communications materials, like New York, or an FAQ for consumers, like Ohio.

Georgetown University’s Center for Children and Families (CCF) tracks state unwinding resources across the county. States are also engaged in some innovative coverage policy solutions intended to mitigate the coverage losses during the unwinding, like Oregon’s bridge plan, and auto-enrollment from Medicaid into state-based marketplaces as California and Rhode Island are planning to do.

Tools and Resources

When states begin Medicaid redeterminations, it will be an all-hands-on-deck effort to ensure that people don’t lose coverage erroneously. Here are some helpful tools to help state Medicaid offices, health care systems, community organizations, and enrollment assisters in this effort.

• CMS has released a communications toolkit in many languages to help states and partner organizations get the word out to Medicaid enrollees about what has happened and what is coming. The toolkit has been recently updated to reflect that the redetermination process is no longer tied to the PHE.
• CMS has also been holding regular webinars (archived here) to help states and assisters prepare for the unwinding.
• Center on Budget and Policy Priorities’ Beyond the Basics has an FAQ and tipsheet for community partners (in eight languages).
• Georgetown CCF, in addition to its 50-state unwinding tracker, has a multitude of blogs to stay abreast of recent developments in the unwinding.

Connect with Us

Navigating the new landscape of Medicaid eligibility can be confusing — but Transform Health is here to help. If you would like to learn more about the ramifications of Medicaid unwinding, or want to work with Transform Health, please contact Heather Bates heather@transformhc.com. For media inquiries, please contact Elizabeth Wells elizabeth@transformhc.com.