27 Jun PHE FFCRA Medicaid Eligibility Redeterminations
In January 2020, the Department of Health and Human Services declared COVID-19 a public health emergency. Since then, the PHE has been renewed nine times, but it is scheduled to expire in August unless it is extended again. Its end will have a major effect on Medicaid, when one considers that millions of program recipients will lose the coverage that the PHE and corresponding legislation provided.
Soon after the PHE was declared, Congress passed the Families First Coronavirus Response Act (FFCRA). The legislation worked to provide relief during the course of the pandemic by expanding Medicaid to prevent coverage losses for vulnerable populations while simultaneously giving fiscal relief to states. The FFCRA was able to accomplish this by raising the federal medical assistance percentage (FMAP) by 6.2 percent. In addition, the FFCRA altered the maintenance of eligibility (MOE) requirements by prohibiting states from altering eligibility or removing members from the program, and adjusted enrollment processes until the end of the pandemic.
Because of the changed Medicaid eligibility criteria, enrollment in the Medicaid program surged during the pandemic. A report by KFF estimated that program enrollment grew by 25 percent or 22.2 million enrollees between FY 2019 and FY 2022. Out of those enrolled, MOE enrollment growth represented 18.7 million new enrollees.
With the end of the PHE approaching, states will need to reevaluate their Medicaid budgets considering that they will no longer receive the FFCRA’s increased funding. Moreover, the MOE requirements will expire, and states will need to begin eligibility redeterminations. As a result, KFF estimates that anywhere between 5.3 million and 14.2 million enrollees could lose coverage.
According to Medicaid.gov, this will be the “single largest health coverage transition event since the first open enrollment period of the Affordable Care Act.”
Coordinating benefits to ensure eligible beneficiaries continue receiving coverage during the transition will be crucial. CMS has published guidance to help states with eligibility redeterminations, changes between coverage programs, and returning to normal eligibility and enrollment operations. According to the guidance, states will have 12 to 14 months to conduct redeterminations. Additionally, the Department of Health and Human Services will give a 60-day notice of when the PHE will end to help states prepare.
Considering the surge in Medicaid enrollment because of the FFCRA and the upcoming expiration of provisions, it will be interesting to see how many individuals will remain eligible to receive the Medicaid program’s important health care benefits. In some instances, the circumstances for some individuals will have improved, so they will no longer require assistance. Alternatively, some beneficiaries may be eligible for additional benefits. Eligibility determinations will undeniably be a difficult task for Medicaid plans; nevertheless, it will be an opportunity to ensure that the most vulnerable populations are receiving benefits and that program resources are being preserved.