State officials are actively planning for the eventual end of the Medicaid continuous coverage requirement that is currently associated with the federal COVID-19 public health emergency (PHE) and enhanced federal Medicaid matching funds. The continuous coverage requirement has ensured that individuals enrolled in Medicaid throughout the pandemic are not at risk of losing coverage. However, unwinding this provision will require individuals to complete renewals necessary to redetermine their eligibility to remain in the program. Medicaid officials are focused on ensuring that eligible individuals do not lose coverage when it is time for their renewal.

The timing and federal requirements of unwinding the Medicaid continuous coverage requirement is currently unknown. Federal guidance has been evolving with more, significant, changes expected soon, including reduced federal funding to states. Read more about the proposed changes in this NASHP blog.

The unwinding of Medicaid’s continuous coverage will require significant policy and operational shifts that involve eligibility system and other technological changes. While states will need time to effectuate some of these changes, some are waiting until federal requirements are finalized to operationalize changes to avoid incurring excess costs associated with unnecessary large-scale system changes. In the meantime, state Medicaid officials are seizing opportunities to lay important groundwork including improving communications with members and strengthening partnerships.

Improving address and contact information 

Throughout the pandemic, Medicaid enrollees have not needed to complete renewal process to maintain coverage. Given that the Medicaid continuous coverage provision has resulted in less frequent communication with enrollees, there is widespread concern that states may not have up to date contact information, including addresses for all enrollees. Economic instability due to the pandemic resulted in more people being transient in the last year, exacerbating the likelihood of outdated address information. This could result in eligible individuals losing coverage because they did not receive renewal notices, and therefore they may not take action to return necessary paperwork to the state. In preparation, states are exploring multiple avenues to gather accurate address and contact information for their enrollees, including data sharing agreements with the US Postal Service, as well as other state agencies and public benefit programs.

State agencies are also seeking to enlist assistance from their Medicaid managed care organizations (MCOs) that may have more recent contact information on their enrollees as enrollees may be more actively interacting with their insurance carrier. In recent discussions with state officials about returned, undeliverable mail, several states also indicated that they are exploring contracting with vendors to research more accurate address sources and provide the agency with up-to-date contact information for individuals not receiving state correspondence. In addition, states are working proactively to gather new information at any point of contact with members, including granting new permissions to call center staff who were previously unable to update contact information.

Identifying best practices for outreach and communications

Consumer education is critical to ensuring that individuals are not inappropriately disenrolled from coverage when normal eligibility determination operations resume. Members who newly enrolled in Medicaid coverage during the PHE may be unfamiliar with the Medicaid renewal process and actions typically required to maintain enrollment. Some states are taking added steps to ensure that notices are distinct from communications sent throughout the pandemic and convey the appropriate level of urgency, while also meeting readability standards for their consumers. Some states have engaged community perspectives in drafting communications such as member advisory groups to ensure that messages are effective to help with disseminating communications. 

In addition, states will need to communicate with individuals and families who benefited from coverage premium holidays or other payment flexibilities under a COVID-19 disaster state plan amendment (SPA). As protections adopted under disaster SPAs are tied to the expiration of the PHE, states are beginning to communicate with members to prepare them for upcoming changes. 

Developing strategies for processing and staggering renewals and redeterminations 

States are developing plans to approach the large volume of eligibility redeterminations and verifications they will need to process following the termination of the Medicaid continuous coverage requirement. Most states have continued to process coverage renewals throughout the PHE and many report that there are a significant number of individuals that have not provided necessary information to verify their eligibility. These individuals have not been disenrolled but will need attention as Medicaid unwinds the continuous coverage requirement. States are utilizing different strategies to ensure they will have the capacity and information needed to effectively process renewals. Such strategies include:

• Timing: Several states have expressed the need to stagger these individuals’ renewals over a 12-month period to ensure there isn’t a disproportionate volume of renewals like this every year into the future. Medicaid staff will also need ample time to complete eligibility verifications for individuals that return their renewals, as well as time to act on any reports of changes in circumstance from enrollees that may affect their Medicaid eligibility.
• Staggering renewals: Consistent with federal guidance, some state officials will opt to conduct renewals by prioritizing groups. For instance, some states intend to first identify and process those enrollees who are most likely to be ineligible for Medicaid, and one state indicated that they will prioritize eligibility redeterminations for the optional COVID-19 testing group. 
• Alignment with other eligibility determinations: States adopting the 12-month postpartum coverage option under the American Rescue Plan Act may consider aligning redeterminations for individuals covered under the pregnant persons group until after the coverage expansion has taken effect in April 2022. 

Partnering with state health marketplaces

Some Medicaid agencies in states with state-based marketplaces are partnering to identify strategies to ease the transition to commercial coverage for individuals deemed ineligible for Medicaid. Through consistent communication and collaboration, state Medicaid agencies and health insurance marketplaces are working to mitigate barriers and facilitate shifts into marketplace coverage, including collaborating on shared language used in notices and outreach materials, clear communication on timing of changes, and efforts to share, where possible, appropriate data about enrollees. States are also exploring opportunities and potential benefits of easing transitions between programs, especially where the same carriers participate in both Medicaid and the Marketplace.

As federal direction is finalized on how to unwind the continuous coverage requirement, states will have more information that will allow them to take further action and assist in their planning. In the meantime, they are thoughtfully approaching this huge task and leveraging the resources they have. NASHP will continue to engage states and track their efforts moving ahead.