By Cathy Zhang
The COVID-19 Public Well being Emergency (PHE) expires on the finish of this week, with Division of Well being and Human Providers (HHS) Secretary Xavier Becerra anticipated to resume the PHE as soon as extra to increase via mid-July.
When the PHE finally expires, this may even set off the top of the Medicaid steady enrollment requirement, below which states should present steady Medicaid protection for enrollees via the top of the final month of the PHE in an effort to obtain enhanced federal funding. This coverage improves protection and helps scale back churn, which is related to poor well being outcomes.
After the PHE, states can facilitate easy transitions for these not eligible for Medicaid by making the most of the total 12- to 14- month interval that the Facilities for Medicare & Medicaid Providers (CMS) has established for redetermining eligibility.
In August 2021, CMS launched steerage giving states as much as 12 months following the top of the PHE to redetermine whether or not Medicaid enrollees have been nonetheless eligible and renew protection. Final month, CMS launched new steerage specifying that states should provoke redeterminations and renewals inside 12 months of the PHE ending, however have as much as 14 months to finish them. The company is encouraging states to unfold its renewals over the course of the total 12-month unwinding interval, processing not more than 1/ninth of their caseloads in a month, in an effort to scale back the chance of inappropriate terminations.
What States Are Doing Now
Two weeks after CMS issued its March 2022 steerage, the Kaiser Household Basis launched its annual survey of state Medicaid and Youngsters’s Well being Insurance coverage Program (CHIP). Information for the report was collected in January, earlier than the issuance of the most recent steerage, and displays states’ plans on the time for approaching redetermination and actions taken in anticipation of the unwinding.
Whereas states can not disenroll individuals from Medicaid throughout the PHE, they will take proactive steps to resume protection for present enrollees. By a course of known as ex parte renewal, states can have a look at present information on enrollees to find out if they’re nonetheless eligible for Medicaid, during which case the state will renew their protection with out the enrollee taking any further steps. States are required by legislation to try an ex parte renewal earlier than requesting any varieties or documentation from an enrollee.
The annual survey discovered that 42 states have been already processing ex parte renewals in January. The March CMS steerage additionally encourages states to broaden their information sources for conducting ex parte renewals, which might make it doable to efficiently conduct extra renewals with out requiring additional motion from enrollees.
The annual survey additionally discovered that 46 states have plans to replace enrollees’ addresses earlier than the top of the PHE. Doing so can be sure that extra enrollees truly obtain any renewal varieties they could have to fill out, thereby bettering continuity. To additional enhance the speed of contact for enrollees, 35 states plan follow-up on returned mail by way of phone, e mail, and textual content earlier than terminating protection after the PHE.
Continuity of Protection
Based mostly on information from 20 states, the annual survey discovered that an estimated 13% of present enrollees will lose their Medicaid protection on the finish of the continual enrollment interval.
In an effort to cut back lack of protection, 41 states have indicated they’ll comply with up with enrollees when particular person motion is required to take care of protection. States will not be, nonetheless, required to comply with up with enrollees earlier than terminating protection as soon as a renewal request has been despatched out.
Not all state plans are geared in the direction of maximizing protection, nonetheless. In January, 11 states had plans to focus on people who seem like not eligible first, and 15 states indicated they’d use information to establish and goal enrollees who might not be eligible for precedence motion after the PHE.
Information for Future Policymaking
Together with steerage for the timeline of conducting redeterminations, the brand new CMS steerage requires states to submit month-to-month information on their processing of purposes and renewals for a minimum of 14 months. Along with guaranteeing compliance with the timeline necessities for the unwinding interval, this will empower policymakers to quantify the consequences of steady enrollment, in addition to completely different approaches to renewals, to make long-term methods for bettering protection.