The End of Medicaid Continuous Enrollment & the Impact on Providers
In response to the COVID-19 pandemic, congress enacted the Families First Coronavirus Response Act (FFCRA) to provide employees with paid sick leave and expanded family/medical leave. It also included a requirement for Medicaid to maintain continuous enrollment for recipients until the end of the COVID-19 Public Health Emergency (PHE). Continuous enrollment allowed Medicaid beneficiaries to keep their healthcare coverage without reevaluating their income or economic circumstances. This provision was significant as many individuals faced financial hardships and increased healthcare needs due to the ongoing crisis.
As the COVID-19 situation has evolved and vaccination efforts have progressed, some states began to phase out the continuous enrollment policy for Medicaid beneficiaries. On December 29, 2022, congress signed into law a Consolidated Appropriations Act 2023, which set the end of continuous enrollment provision on March 31, 2023. This change is important for providers because Medicaid enrollment has increased substantially during the PHE. The Kaiser Family Foundation (KFF) [1], using data from The Centers for Medicare and Medicaid (CMS), estimates Medicaid/CHIP (Children's Health Insurance Program) enrollment has increased by more than 20 million (28.5%) since February 2020. Additionally, The Kaiser Family Foundation believes that many people who will be disenrolled by the end of continuous enrollment could become uninsured for a portion of the next twelve months[2].
In anticipation, CMS has issued guidance for providers to prepare for the event[3]. It stresses the importance of conducting outreach to enrollees to update mailing and contact information to ensure current enrollees receive renewal forms and program information to either:
a. Remain in Medicaid
b. Transition to Basic Health Plan (BHP) or the Affordable Care Act (ACA) marketplace for coverage.
Every break in coverage runs the risk of patients becoming uninsured and, ultimately, a revenue write-off for the provider.
The end of Medicaid's continuous enrollment signifies a significant shift in the healthcare landscape. Providers should proactively engage with their patients, adapt their administrative processes, and collaborate with Medicaid agencies to ensure the continuity of care for vulnerable populations and mitigate any potential disruptions in healthcare access.
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[1] 1 “Analysis of Recent National Trends in Medicaid and CHIP Enrollment”, March 22, 2023, Kaiser Family Foundation website [2] “As States Prepare to Unwind...”, January 25, 2023, Kaiser Family Foundation website [3] “CMS SHO#22-001 Promoting Continuity of Coverage...Upon the Conclusion of the COVID-19 Public Health Emergency”, March 3, 2023
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