The Biden-Harris Administration recently took another step to ensure access to comprehensive health care coverage by providing states with guidance as they plan for whenever the COVID-19 Public Health Emergency (PHE) does conclude. The Centers for Medicare & Medicaid Services (CMS) guidance will help states keep consumers connected to coverage by either renewing individuals’ Medicaid or Children’s Health Insurance Program (CHIP) eligibility or helping them look at other affordable federal and state-based health insurance options.
The Biden-Harris Administration is clear that continuing to protect against COVID-19, ensuring that our response remains nimble, and ensuring a smooth transition at the eventual end are top priorities. Since the beginning of the Administration, the Department of Health and Human Services (HHS) has committed that it will provide states 60 days’ notice before any planned expiration or termination of the PHE to provide states with as much lead time as possible to plan for the eventual end of the PHE.
During the Public Health Emergency, enrollment in Medicaid and CHIP has grown by over 14 million and reached record highs – nearly 85 million people as of September 2021. As a condition of receiving enhanced federal funding, states agreed not to terminate enrollment for most individuals enrolled in Medicaid from March 2020 through the end of the month in which the PHE concludes. Given these flexibilities and the process of returning to normal operations at the end of the PHE, most individuals will have to go through the Medicaid/CHIP eligibility renewal process for the first time in months or years when the PHE eventually ends.
CMS’ new guidance aims to make sure states are well-prepared to initiate eligibility renewals for all individuals enrolled in Medicaid and CHIP within 12 months of the eventual end of the PHE, and to complete renewals within 14 months. To help consumers maintain coverage, the guidance also emphasizes current rules requiring states to provide a smooth transition to other options for those who may no longer be eligible for Medicaid or CHIP once the PHE eventually ends. CMS remains committed to working with state and federal partners to ensure renewals and transitions between programs result in as little disruption to individuals as possible.
CMS’ new guidance provides planning and reporting tools that offer states a roadmap to:
- Restore routine eligibility and enrollment operations after the PHE ends;
- Promote continuity of coverage; and
- Facilitate transitions between Medicaid, CHIP, the Basic Health Program, and the Health Insurance Marketplaces.
CMS is also providing states with an Eligibility and Enrollment Planning tool which will aid states’ planning to maintain Medicaid coverage for eligible individuals and ensure a smooth transition to pre-PHE operations.
CMS is also releasing a PHE Unwinding toolkit for states and groups that assist people with Medicaid coverage to help beneficiaries through the eligibility renewal process. This toolkit, which will be updated as needed, includes key messages, social media, outreach products, email templates, text message templates, and call center scripts.
Finally, the agency refreshed its slide deck highlighting the role Managed Care Organizations can play in supporting states in their efforts to reach people with Medicaid coverage during the PHE Unwinding period. Now, the slide deck includes additional information on using plans to collect beneficiaries’ contact information, strategies to consider when people enrolled in Medicaid lose coverage, and other updates that clarify the federal framework for engaging plans in PHE Unwinding efforts. Health plans are critical partners in this work, and CMS strongly encourages states to utilize plans to conduct outreach and engage with beneficiaries during the renewal process – including outreach to individuals who have lost Medicaid coverage.
This recent guidance marks the latest in a series of updates from CMS to help states prepare for “unwinding” the policy flexibilities adopted during the COVID-19 PHE. In August 2021, CMS issued guidance that addressed several earlier concerns, including doubling the timeframe allowed for states to address pending eligibility and enrollment actions from six to 12 months. In 2021, the agency also released three practical tools:
- Strategies States and U.S. Territories Can Adopt to Maintain Coverage of Eligible Individuals as they Return to Normal Operations, which offers a “punch list” of tactics to help states maintain continuity of coverage;
- A Connecting Kids to Coverage issue brief, which highlights effective and practical strategies to improve state Medicaid and CHIP outreach, enrollment, and renewal; and
- A Risk Assessment Webinar and Toolkit for Evaluating COVID-19 Flexibilities and Waivers, which lays out an approach for states to use when assessing and planning for potential risks related to “unwinding,” including beneficiary eligibility and enrollment policies.
For access to these and other resources, including the guidance recently issued, visit CMS’ comprehensive Medicaid Unwinding webpage.
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