Read this if you are at a state Medicaid agency.
As the end of the Public Health Emergency becomes more likely, much attention has been paid to the looming coverage cliff as state Medicaid agencies re-determine eligibility for their programs. The impacts can be mitigated in part by planning and taking proactive steps.
In the unsettling initial days of the COVID-19 Public Health Emergency (PHE), the Centers for Medicare and Medicaid Service (CMS) temporarily increased federal matching funds for state Medicaid programs. In exchange, states would suspend redeterminations of enrollees’ eligibility for the duration of the PHE.
For Medicaid, states were in effect prohibited from disenrolling an individual from Medicaid programs. The result, according to CMS data, is 14.8 million more people were enrolled in Medicaid as of late 2021 than before the pandemic, reaching a total of nearly 79 million Medicaid enrollees. According to one estimate, the end of the PHE could bring a decline in the number of Medicaid enrollees by as many as 15 million. This number includes an estimated 8.7 million adults and 5.9 million children.
Local and state government eligibility staff will need to review the submitted documents and determine if these members qualify for continued Medicaid coverage. The potential exists for members to lose coverage, due to factors such as having moved, not realizing their circumstances have otherwise changed, or being unable or unaware to return the required paperwork within appropriate timeframes.
State Medicaid agencies strive to maintain an equitable program while remaining trusted stewards of public funds. With a large base of beneficiaries, this change is expected to impact the community and the healthcare market, with broad implications for public health. Similarly, the federal requirement for continuous health coverage has also helped state Medicaid agencies by easing the strain on organizations during pandemic-related disruptions.
For these reasons state Medicaid agencies may search for routes to limit the loss of coverage. This can be accomplished through finding policy levers to retain members, establishing routes to alternative forms of insurance, and mitigating the risk of coverage loss for members.
Mitigating the likelihood of becoming uninsured
State Medicaid agencies can reduce the risk that members lose their coverage and become uninsured through a number of steps.
- Designing comprehensive, multi-pronged, and targeted communication strategies. States can help Medicaid members understand the requirements and timelines required to maintain their coverage.
- Updating systems to automate and reduce administrative burden. Maximizing ex parte renewals through the use of existing data that is stored in integrated systems.
- Making key decisions early. States can minimize coverage loss by carefully planning the unwinding process and their approach to resuming Medicaid eligibility renewals.
- Coordinating with other forms of coverage. Confirm or design user-friendly pathways by which a member is transferred or referred to other alternatives like the Marketplace or CHIP.
- Leveraging their health plans. Particularly when it comes to coordinating outreach and updating member information. Managed care plans are also able to refer members who are losing coverage to other qualified health plans.
Policy levers for retaining members
States may consider reviewing emergency state plan amendments and appendix k amendments completed during the PHE to determine what flexibilities are possible to continue under existing authorities. At the same time, states should consider what other policy options may help retain coverage for existing members- for example:
- Adopt 12 months continuous eligibility. This can be done for children via a State Plan Amendment (SPA), for adults through an 1115 waiver, and for individuals enrolled in BHP (via BHP Blueprint revision)
- Establish 12 months of postpartum coverage. This can be done through several paths, including SPAs
- Review operational policy for efficiencies. For example, a State could consider modifying the frequency of periodic data matching
Next steps
The US Department of Health and Human Service has previously indicated its intention to provide notification to states of the end of the PHE 60 days before its scheduled end. The PHE was renewed in April 2022, and as of this writing will last until mid-July, meaning enrollees could lose Medicaid coverage as soon as August 1. The enhanced FMAP and the Maintenance of Eligibility (MOE) requirements are in place until the end of the quarter in which the PHE ends. In the case of a July 2022 end date to the PHE, the enhanced FMAP would last through September 30, 2022.
Regardless, Medicaid agencies will need to begin reviewing all enrollees’ eligibility, performing outreach, and designing system updates this summer. In terms of next steps, states should consider the following:
- Evaluate your program and identify initiatives to prioritize in the coming year. Ask your CMS contact about the latest applicable guidance.
- Develop Advanced Planning Documents (APDs) to help fund technology needs for initiatives, along with training your SMA team and providers.
- Implement a communications management approach to engage stakeholders, and inform affected Medicaid members.
- Marshal project management resources and develop a realistic and achievable roadmap to success.
- Explore agency contracting vehicles, cooperative contracts, and other procurements tools.
We’re here to help. If you have more questions or want to have an in-depth conversation about your specific situation, please contact the Medicaid consulting team.