But this will not happen all at once, as each state will have its own approach to the resumption of eligibility redeterminations. CMS guidance also outlines specific steps states can take, including ensuring accessibility of forms and notices for people with LEP and people with disabilities and reviewing communications strategies to ensure accessibility of information. It also provides states more time to prepare for new rules that will put millions in jeopardy of losing their health insurance, something state Medicaid directors have been demanding from legislators. Opens in a new window. This provision requires states to provide continuous coverage for Medicaid enrollees until the end of the month in which the public health emergency (PHE) ends in order to receive enhanced federal funding. 2716, the Consolidated Appropriations Act (CAA) for Fiscal Year 2023. President Biden says the emergency order will expire May 11. As a result, in order for these waivers to continue, Congress must act and pass legislation making these waivers permanent. A majority of states also indicated they were taking steps to update enrollee contact information and were planning to follow up with enrollees before terminating coverage. The COVID SEP ended in most states. including education, public health, justice, environment, equity, and, . The non-partisan Congressional Budget Office assumes the public health emergency for Covid is set to expire in July. The PHE is expected to continue until mid-May 2023. Share this: . However, when states do need to follow up with enrollees to obtain additional information to confirm ongoing eligibility, they can facilitate receipt of that information by allowing enrollees to submit information by mail, in person, over the phone, and online. An Informational Bulletin (CIB) posted on January 5, 2023 included timelines for states to submit a renewal redistribution plan. Some of these waivers had previously expired, but ANA is still advocating to change the law and make them permanently part of the Medicare program. For system readiness reporting, states are required to demonstrate that their eligibility systems for processing renewals are functioning correctly, particularly since states have not been conducting normal renewals while the continuous enrollment provision has been in effect. CMS notes in recent guidance that states can increase the share of ex parte renewals they complete without having to follow up with the enrollee by expanding the data sources they use to verify ongoing eligibility. The powers activated by the emergency. endstream endobj startxref By preventing states from disenrolling people from coverage, the continuous enrollment provision has helped to preserve coverage during the pandemic. The temporary loss of Medicaid coverage in which enrollees disenroll and then re-enroll within a short period of time, often referred to as churn, occurs for a several reasons. Primarily due to the continuous enrollment provision, Medicaid enrollment has grown substantially compared to before the pandemic and the uninsured rate has dropped. Follow @meg_ammula on Twitter First, the maintenance of effort provisions in the Families First Coronavirus Response Act remain in effect until January 31, 2022 (the end of the month after the PHE ends). Even though Congress could still enact some version of the BBB provisions relating to the unwinding of the continuous enrollment requirement, some states would find an April 1, 2022 renewal start date challenging. Importantly, the legislation requires these reports be made publicly available. If you have questions or comments on this service, please contact us. Lastly, states are required to maintain up to date contact information and attempt to contact enrollees prior to disenrollment when mail is returned. If the PHE ends in April 2023, the FFCRAs rules would have resulted in the additional federal Medicaid funding (6.2 percentage points added to a states regular federal Medicaid funding) ending altogether at the end of June 2023. Especially after reports showing worsening health outcomes for mothers, investing these funds into extending Medicaid postpartum coverage is critical, said Rep. Robin Kelly (D-Ill.), who leads the health care task force for the Congressional Black Caucus. Throughout the COVID-19 public health emergency (PHE), CMS has used a combination of emergency authority waivers, regulations, enforcement discretion, and sub-regulatory guidance to ensure access to care and give health care providers the flexibilities needed to respond to COVID-19 and help keep people safer. But there are very real concerns that many people who are actually still eligible for Medicaid might lose their coverage due to a lack of understanding of the process, onerous paper-based eligibility redetermination systems, unstable housing/communication situations, etc. There is a relatively new special enrollment period that allows people with household income up to 150% of the poverty level to enroll in coverage year-round, for as long as the enhanced subsidies remain in place (so at least through the end of 2025, and possibly longer if Congress grants another extension). As part of the Consolidated Appropriations Act, 2023, signed into law on December 29, 2022, Congress set an end of March 31, 2023 for the continuous enrollment provision, and phases down the enhanced federal Medicaid matching funds through December 2023. The continuous coverage provision increased state spending for Medicaid, though KFF has estimated that the enhanced federal funding from a 6.2 percentage point increase in the federal match rate (FMAP) exceeded the higher state costs. For a person who is no longer Medicaid-eligible under normal rules, Medicaid coverage can end as early as April 1, 2023. During the PHE, Medicaid agencies have not disenrolled most members, even if someone's eligibility changed . Most of the people who will become eligible for marketplace subsidies will be adults, as children are always much less likely than adults to qualify for marketplace subsidies. This is true regardless of whether youll qualify for the new low-income special enrollment period, since youll have a normal loss-of-coverage special enrollment period when your Medicaid ends, and you can take advantage of it right away. Some people who will lose Medicaid eligibility are now eligible for Medicare instead. She has written dozens of opinions and educational pieces about theAffordable Care Actfor healthinsurance.org. According to a survey of non-profit, safety net health plans that participate in Medicaid, states are partnering with these MCOs in multiple ways. 10 Things to Know About the Unwinding of the Medicaid Continuous Enrollment Provision, 10 Things to Know About Medicaid Managed Care, FAQs on Health Spending, the Federal Budget, and Budget Enforcement Tools, Health Insurer Financial Performance in 2021. If CMS determines a state is out of compliance with any applicable redetermination and reporting requirements, it can require the state to submit a corrective action plan and can require the state to suspend all or some terminations due to procedural reasons until the state takes appropriate corrective action. States can also work with community health centers, navigators and other assister programs, and community-based organizations to provide information to enrollees and assist them with updating contact information before the continuous enrollment period ends, completing the Medicaid renewal process, and transitioning to other coverage if they are no longer eligible. Other than that, if you miss the special enrollment period for your particular coverage, youll have to wait until the next annual open enrollment period to sign up for coverage (employers set their own annual enrollment windows; Medicares general enrollment period is January March each year). Under the ACA, states must seek to complete administrative (or ex parte) renewals by verifying ongoing eligibility through available data sources, such as state wage databases, before sending a renewal form or requesting documentation from an enrollee. ts noteworthy that the additional federal Medicaid funding that states have received is. People using this window can elect to have their Medicare coverage retroactive to the day after their Medicaid ended, although any back premiums would have to be paid in that case. Some have described this as the single largest enrollment event since the Affordable Care Act. You can share your story about the impact of the Public Health Emergency HERE. On March 18, 2020, the Families First Coronavirus Response Act was signed into law. But they could choose to do so, and could also choose to waive premiums for CHIP during that time. NOTE: States may not elect a period longer than the Presidential or Secretarial emergency declaration . But our goal today is to help you understand what you need to know in order to maintain coverage if youre one of the millions of people who could potentially lose Medicaid eligibility in the coming months. for medical reasons related to the disaster or public health emergency, or who are otherwise absent from the state . Some people who will lose Medicaid eligibility are now eligible for Medicare instead. The Center for Children & Families (CCF), part of the Health Policy Institute at the McCourt School of Public Policy at Georgetown University, is a nonpartisan policy and research center with a mission to expand and improve high-quality, affordable health coverage. The Biden administration announced its intention to end the federal public health emergency on May 11, 2023. This brief provides an overview of the major health-related COVID-19 federal emergency declarations that have been made, and summarizes the flexibilities triggered by each in the following. But because Democrats are squeamish about this, theyre going to use it to drive a hard bargain. On January 30, 2023, the Biden administration announced its intention to make final extensions of both the COVID-19 National Emergency (NE) and the COVID-19 Public . Both . Can you appeal your states decision to disenroll you? This enrollment growth more than 27% in a little over two and a half years was initially tied to the widespread job and income losses that affected millions of Americans early in the COVID pandemic. Lawmakers and staff have been scrambling for weeks to find ways to pay for a slew of health care programs, such as permanent telehealth flexibility, providing longer Medicaid coverage for new mothers and avoiding scheduled cuts to doctors payments, prompting formerly resistant Democratic members to take a fresh look at moving up the end-date of the Covid-19 Medicaid policy by at least three months to April 1. While the PHE ends on May 11, in payments rules CMS has extended the waivers for an additional 152 days to allow providers time to undo the waivers. As states return to routine operations when the continuous enrollment provision ends, there are opportunities to promote continuity of coverage among enrollees who remain eligible by increasing the share of renewals completed using ex parte processes and taking other steps to streamline renewal processes (which will also tend to increase enrollment and spending). | T p{YWY4,;U|p9 It can be allowed to expire at the end of the 90-day period or terminated early if deemed appropriate. States can also consider sharing information on consumers losing Medicaid who may be eligible for Marketplace coverage with Marketplace assister programs; however, in a recent survey, few assister programs (29%) expected states to provide this information although nearly half were unsure of their states plans. For people whose income has increased enough to make them ineligible for Medicaid, but still eligible for this special enrollment period, there will be more flexibility in terms of access to coverage. Your email address will not be published. Many states have continued to send out these renewal notifications and information requests throughout the pandemic (nearly all states have been conducting automatic (ex parte) renewals when possible, and more than half the states have also been sending renewal forms to enrollees). Some states suspended renewals as they implemented the continuous enrollment provision and made other COVID-related adjustments to operations. Doing so would decrease federal spending on Medicaid and allow states to remove ineligible people from the program, saving the government tens of billions of dollars. The Administration has stated that payments will resume either sixty days after the Supreme Court renders an opinion or June 30, whichever comes first. There will also be continued access to pathways for emergency use authorizations (EUAs) for COVID-19 products (tests, vaccines, and treatments) through the Food and Drug Administration (FDA), and major telehealth flexibilities will continue to exist for those participating in Medicare or Medicaid. Without other action, states can start disenrolling people beginning May 1, 2022. In the third quarter, it will drop to 2.5 percentage points, and in the fourth quarter of 2023, states will receive 1.5 percentage points in additional federal Medicaid funding. Earlier today, HHS Secretary Becerra renewed the COVID-related public health emergency (PHE). The non-partisan Congressional Budget Office assumes the public health emergency for Covid is set to expire in July. Share on Facebook. Enrollees may experience short-term changes in income or circumstances that make them temporarily ineligible. HHS Secretary Xavier Becerra last renewed the COVID public health emergency on Jan. 11, 2023. What does this mean for Medicaid? US Department of Health and Human Services Secretary Xavier Becerra . The proposed eligibility and enrollment rule aims to smooth transitions between Medicaid and CHIP by requiring the programs to accept eligibility determinations from the other program, to develop procedures for electronically transferring account information, and to provide combined notices. For everyone enrolled in Medicaid as of March 31, 2023, states must initiate the renewal process no later than March 31, 2024. The COVID-19 pandemic cast a spotlight on the importance of the various safety net systems that the U.S. has in place. The Centers for Medicare & Medicaid Services (CMS) has released numerous guidance documents and tools designed to help states. Importantly, these findings also show that large shares of enrollees (41% in the KFF analysis) reenroll in Medicaid after a period of time, and many after a period of uninsurance. However, we know Congress is considering delinking the FMAP bump and continuous enrollment and other maintenance of effort provisions from the PHE. Healthcare Dive reports that the majority of people with Medicaid do not know that their coverage could end when the public health emergency ends. The public health emergency expanded Medicaid coverage eligibility - now that expansion may be going away. States that fail to comply with these reporting requirements face a reduction in federal medical assistance percentage (FMAP) of up to one percentage point for the quarter in which the requirements are not met. CMS is releasing the 2022-2023 Medicaid Managed Care Rate Development Guide for states to use when setting rates with respect to any managed care program subject to federal actuarial soundness requirements during rating periods starting between July 1, 2022 and June 30, 2023. Under normal circumstances, they would have lost their Medicaid eligibility upon turning 65, as the, that allows for a six-month special enrollment period during which a Medicare-eligible person who loses Medicaid coverage can transition to Medicare without a late enrollment penalty. The Department of Health and Human Services (HHS) has extended the public health emergency eight times and is currently set to expire in April 2022. As part of a Covid-19 relief package passed in March 2020, states were barred from kicking people off Medicaid during the public health emergency in exchange for additional federal matching funds. At the start of the pandemic, Congress enacted the Families First Coronavirus Response Act (FFCRA), which included a requirement that Medicaid programs keep people continuously enrolled through the end of the month in which the COVID-19 public health emergency (PHE) ends, in exchange for enhanced federal funding. Amid tense arguments about how to spend the savings from the expedited end to the Medicaid portion of the PHE, lawmakers have also struggled over whether and how to set up guardrails to protect people who make slightly too much to qualify for Medicaid from being left without a private health insurance plan they can afford in 2023. Published: Feb 22, 2023. Republicans have long called for ending the public health emergency for Covid-19 and have forced a handful of successful Senate votes that were then blocked in the House. During the PHE, Medicaid enrollees automatically stayed enrolled in Medicaid and did not have to constantly keep proving eligibility. Findings This cohort study of 4869 Latina patients with gestational (n = 2907) or preexisting diabetes (n . Starting April 1, 2023, states can resume Medicaid disenrollments. Efforts to conduct outreach, education and provide enrollment assistance can help ensure that those who remain eligible for Medicaid are able to retain coverage and those who are no longer eligible can transition to other sources of coverage. Meghana Ammula The overriding thing state Medicaid agencies want is certainty about what is coming, Jack Rollins, the director of federal policy for the National Association of Medicaid Directors, told POLITICO. According to an Urban Institute analysis, about a third of the people losing Medicaid will be eligible for premium tax credits (subsidies) in the marketplace, while about two-thirds will be eligible for employer-sponsored coverage that meets the ACAs definition of affordable. The U.S. Department of Health and Human Services (HHS) must renew the federal public health emergency (PHE) related to COVID-19 every 90 days to maintain certain health care flexibilities and waivers. One note about the Childrens Health Insurance Program (CHIP): States that operate a separate CHIP were not required to suspend CHIP disenrollments during the pandemic. Ensuring accessibility of information, forms, and assistance will be key for preventing coverage losses and gaps among these individuals. Congress has extended the telehealth flexibility through the end of 2024, but it is unclear if it will be extended further or made permanent. As states prepare to complete redeterminations for all Medicaid enrollees once the continuous enrollment provision ends, many may face significant operational challenges related to staffing shortages and outdated systems. The Biden administration appears headed toward extending the COVID-19 public health emergency for another three months, allowing special powers and programs to continue past the midterm election. Can I use my Medicaid coverage in any state? (As well discuss in a moment, the Consolidated Appropriations Act, 2023, has changed this rule). 3168 0 obj <> endobj during which you can transition to Medicare without any late enrollment penalties. The current PHE ends January 16, 2022, so a 90-day extension takes us to April 16, 2022. But the overall pace of Medicaid eligibility redeterminations and disenrollments will vary considerably from one state to another. If youve recently submitted renewal information to your state and its clear that youre still eligible, your coverage will continue as usual until your next renewal period. This would have incentivized some states to act as quickly as possible to disenroll people from Medicaid. Medicaid enrollment increased by over 17 million from February 2020 to May 2022. 2716, the Consolidated Appropriations Act (CAA) for Fiscal Year 2023. A TRUSTED INDEPENDENT HEALTH INSURANCE GUIDE SINCE 1994. Democrats, in contrast, have been hesitant to tie the administrations hands as the virus continues to kill hundreds of people each day and a winter surge of several illnesses strains the countrys medical system. Moreover, research shows that when parents gained coverage under the Medicaid expansion, Medicaid participation among their eligible but unenrolled children also increased. The main point to keep in mind is that the opportunity to transition to new coverage, from an employer, Medicare, or through the marketplace, is time-limited, although the unwinding SEP described above (announced in late January 2023) gives people significantly more flexibility in terms of being able to enroll in a plan through HealthCare.gov after losing Medicaid during the 16-month window that starts March 31, 2023. And did not have to constantly keep proving eligibility is set to expire in July enrollment provision and made COVID-related! 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