As the COVID-19 public health emergency once again appears, at least for the moment, to be winding down, state governments are preparing for how to undo the Medicaid and Children’s Health Insurance Program expansions mandated by Congress and return to their pre-COVID eligibility criteria for the two major health care safety-net programs.

Under the temporary federal expansion of Medicaid and CHIP eligibility during the pandemic’s early days, states received enhanced federal matching funds for those programs in exchange for expanding their eligibility criteria and agreeing not to reconsider enrollees’ eligibility for the duration of the PHE.  With the prospect of that end now on the horizon, states are beginning to consider how they might go about reevaluating beneficiaries’ eligibility and paring their Medicaid and CHIP rolls.

With this situation in mind, the Kaiser Family Foundation and the Georgetown University Center for Children and Families surveyed the 50 states to see how they planned to go about what promises to be a challenging process.  Among their findings (taken directly from their published report):

  • States are required to develop plans for how they will prioritize outstanding eligibility and renewal actions when the continuous coverage requirement is lifted; just over half of states (27) have determined their approach.
  • Fifteen states indicate they will conduct electronic data matches to identify and target enrollees for priority action who may no longer be eligible after the continuous enrollment requirement is lifted.
  • The majority of states (39) plan to take up to a full year to process redeterminations and return to routine operations; however, nine states plan to resume normal operations more quickly.
  • When the continuous enrollment requirement is lifted, a majority of states (41) plan to follow-up with enrollees when action must be taken to avoid a loss of coverage due to missing information.
  • In preparation for the end of the PHE, states are taking steps to update enrollee mailing addresses.
  • Anticipating the need for additional staff resources at the end of the PHE, 30 states plan to take steps to boost staff capacity.
  • Most states are able to report key metrics needed to monitor the unwinding process.
  • In 20 states able to report, it is estimated that about 13% of Medicaid enrollees will be disenrolled when the continuous enrollment requirement ends.
  • Even during the PHE, states continue to streamline application processes and integrate non-MAGI [modified adjusted gross income] and non-health programs into the system that determines MAGI Medicaid eligibility.
  • While states cannot disenroll people, as of January 2022, most states (42) report processing ex parte renewals and sending renewal forms (30 states) to reduce backlogs in renewals at the end of the PHE. 
  • As of January 2022, Medicaid and CHIP eligibility was stable as the PHE protections remained in effect for the entirety of 2021.
  • Recent CMS guidance provides guardrails and flexibilities for states to promote continuity of coverage during the unwinding period; however, state decisions and actions will have implications for Medicaid enrollment.
  • The fate of the Build Back Better Act (BBBA) will have implications for overall coverage.

Learn more about what states are doing to prepare to tackle Medicaid enrollment when the PHE ends in this Kaiser Health News story and the full Kaiser/Georgetown report Medicaid and CHIP Eligibility and Enrollment Policies as of January 2022: Findings from a 50-State Survey.”