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The End of the COVID-19 Public Health Emergency and Medicaid Coverage Redeterminations: A Guide for Counselors
March 7, 2023 by NBCC Government Affairs

Why It Matters: The Public Health Emergency (PHE) declared in response to the COVID-19 pandemic and the array of policy changes it enacted have been in place since March 2020. The Families First Coronavirus Response Act (FFCRA) prohibited states from disenrolling any Medicaid recipient during the PHE to provide “continuous coverage.” In return, states received an enhanced federal reimbursement from Medicaid. 

As part of the Consolidated Appropriations Act, 2023, signed into law Dec. 29, 2022, Congress ended the PHE effective March 31, 2023, discontinuing the continuous coverage policy and the state reimbursements. The process of “unwinding” the policies created under the PHE and resuming “regular operations” brings a great deal of uncertainty for mental health and health care providers, and for Medicaid recipients.

By the Numbers: During the 3 years the PHE and continuous coverage policies have been in place, the number of Americans on Medicaid and the Children's Health Insurance Program (CHIP) grew by nearly 28% to 91 million, according to an analysis by the Kaiser Family Foundation. Kaiser and the U.S. Department of Health and Human Services (HHS) have estimated that up to 14.2 million to 15 million Medicaid and CHIP enrollees could lose their health insurance coverage during the unwinding—the coverage redetermination process—scheduled to begin this month.

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Reality Check: The plan as required by the federal government is to take a year to unwind this pandemic program, but the first termination notices could be mailed on April 1 to hundreds of thousands of Medicaid and CHIP beneficiaries.

When the continuous enrollment provision ends and states resume redeterminations and disenrollments, certain individuals will be at increased risk of losing Medicaid coverage or experiencing a gap in coverage due to barriers to completing the renewal process, even if they remain eligible for coverage. For example, churn rates—where people move in and out of coverage eligibility—increased among children of all racial and ethnic groups, but the increase was largest for Hispanic children, suggesting they face greater barriers to maintaining coverage. Additionally, people with Limited English Proficiency (LEP) and people with disabilities are more likely to encounter challenges due to language and other barriers accessing information. 

Eligibility and renewal systems, staffing capacity, and investment in end-of-PHE preparedness vary across states. HHS is working with states to facilitate enrollment in alternative sources of health coverage and minimize administrative churning. These efforts could reduce the number of eligible people losing Medicaid compared to the estimates above.

How Should Medicaid and CHIP Beneficiaries Prepare? The most important thing Medicaid enrollees can do is make sure their contact information is up to date with Medicaid state agencies where they live. If an enrollee has moved during the pandemic, Medicaid might not have their current address, and eligibility letters and requests for additional information will be sent to the address on file. A failure to respond may result in a loss of coverage. As a rule, many states have a process in place that no individual will be disenrolled without an eligibility redetermination or two failed attempts to obtain verification from the enrollee. Individuals should contact their state Medicaid offices to ensure the department has the most up-to-date information. 

Some people who are no longer eligible for Medicaid may have the option of enrolling in their employer's health insurance plan. Everyone else will have to purchase health insurance through the federal government (Affordable Care Act) or through individual state exchanges and marketplaces.

State Medicaid departments should automatically transfer files to the federal marketplace, and all notices of termination should contain contact information for the federal marketplace navigators who can assist with finding alternative coverage. One important caveat to the unwinding is that children can still be eligible even if their parents or caretaker are not.

The Centers for Medicare & Medicaid Services (CMS) is working closely with state Medicaid agencies, marketplaces, navigators and assisters, beneficiary and consumer advocates, health plans, agents and brokers, departments of insurance, and others as part of a stakeholder engagement strategy to ensure that individuals remain covered.

What Can Counselors Do? There are several ways counselors can assist their Medicaid and CHIP clients during this period:

  • Update contact information for clients who are enrolled in Medicaid and CHIP to increase the likelihood that they will receive notification when it is time to complete redetermination. 
  • Be familiar with your state’s redetermination plan. If a process has not been determined, seek opportunities to describe specific challenges your clients may experience and suggest strategies for avoiding inappropriate disenrollments. 
  • Collaborate with local Medicaid staff to help complete applications for your clients in real time. 
  • Develop a guide for clients with steps they must take to prevent a lapse in their benefits and discuss with them so they are aware. Visit your state Medicaid website for more information.
  • Advocate for proactive redetermination processes in your state.

The Bottom Line: The end of the COVID-19 PHE and the resulting Medicaid redeterminations of all enrollees could have a significant impact on people with mental health conditions and the counselors who serve them. The lack of a stable mailing addresses, changing contact information, and other factors could create challenges for states to accurately redetermine eligibility. However, counselors who implement proactive strategies to overcome these barriers can help ensure greater continuity of coverage for their clients.

NBCC will continue to provide updates on the Medicaid and CHIP unwinding process over this year and how you can help your clients maintain coverage.

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