Unwinding the Medicaid Continuous Enrollment Provision: What Medicaid Beneficiaries Need to Know and Potential Impacts

Since the start of the pandemic, Medicaid enrollment witnessed a substantial increase, largely due to the implementation of the continuous enrollment provision. This provision, part of the Families First Coronavirus Response Act (FFCRA), ensured uninterrupted Medicaid coverage for enrollees during the COVID-19 public health emergency (PHE), supported by enhanced federal funding.

However, with the PHE’s end and the unwinding of the continuous enrollment provision, there are crucial aspects that Medicaid beneficiaries need to understand and potential impacts they may face.

1. Medicaid Enrollment Surge: The continuous enrollment provision resulted in an estimated 23.3 million to nearly 95 million individuals being enrolled in Medicaid/CHIP between February 2020 and March 2023. The provision prevented “churn,” where beneficiaries might lose coverage due to short-term changes in circumstances or procedural issues. It played a significant role in stabilizing Medicaid enrollment and reducing the uninsured rate during the pandemic.
2. Unwinding of the Provision: With the Consolidated Appropriations Act, 2023, the continuous enrollment provision was delinked from the PHE and ceased on March 31, 2023. This allowed states to resume disenrollments and potentially roll back the coverage gains achieved during the pandemic. KFF estimates that between 7.8 million and 24.4 million people, a decline of 8% to 28% in enrollment, could lose Medicaid coverage during the unwinding period.
3. Impact on Medicaid Beneficiaries: Medicaid beneficiaries must be aware of the changes and potential impacts. States vary in their approach to the unwinding process, and renewal requirements may differ. Beneficiaries should stay informed about their state’s specific guidelines and renewal timelines to avoid coverage disruptions.
4. Vulnerable Groups at Risk: Certain groups, including immigrants, individuals with limited English proficiency, people with disabilities, and older adults, may face challenges during the unwinding process. Renewal barriers could lead to potential coverage gaps for these vulnerable populations. It is essential for them to update their contact information and respond to renewal requests promptly.
5. Potential Increase in Uninsured Rate: As millions of individuals are expected to lose Medicaid coverage, there could be a rise in the uninsured rate. The Congressional Budget Office (CBO) projects that 6.2 million people will become uninsured due to disenrollments over the next 18 months. It is crucial for beneficiaries to explore other health coverage options, such as ACA Marketplace plans, to avoid going without health insurance.
6. State Outreach and Assistance: States can play a critical role in easing the unwinding process by partnering with managed care organizations (MCOs) and community health centers to conduct outreach. Beneficiaries should take advantage of available resources and assistance programs to navigate the renewal process successfully.

Conclusion

The unwinding of the Medicaid continuous enrollment provision presents challenges for Medicaid beneficiaries and state agencies alike. Understanding state-specific renewal requirements, timely completion of the renewal process, and exploring alternative health coverage options can help beneficiaries maintain continuity of health care coverage during this transitional period. States must prioritize outreach efforts and streamlined renewal processes to minimize coverage losses and support vulnerable populations. By staying informed and proactive, Medicaid beneficiaries can navigate this phase with greater confidence and ensure access to essential health care services.

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