By: Suzanne Wikle 

UPDATE: In late 2022, Congress passed the Consolidated Appropriations Act and separated the continuous coverage provision from the Public Health Emergency, setting its end date for March 31, 2023.

Since March 18, 2020, people enrolled in Medicaid have been able to keep their coverage, without a requirement to submit renewal paperwork. When the continuous coverage provision implemented as part of the federal COVID-19 response ends later this year, states will be tasked with resuming normal Medicaid renewal operations and Medicaid enrollees will have to complete renewals to maintain coverage. The risk to Medicaid enrollees is significant. An Urban Institute study estimates that 15 million people may lose Medicaid when the continuous coverage provision ends, including more than 6 million children as estimated in a new study from the Georgetown Center for Children and Families.

Continuous coverage has multiple benefits, and since March 2020 it has ensured Medicaid serves as a true safety net for those who are eligible. The continuous coverage provision eased stress for people during the pandemic – their health insurance was stable and they were not at risk of becoming uninsured. States agreed to provide continuous coverage in return for the federal government paying an increased share of Medicaid costs during the pandemic. This agreement between states and the federal government is called the Maintenance of Effort (MOE) requirement and it will end when the Department of Health and Human Services (HHS) declares an end to Public Health Emergency (PHE), currently expected in July.

The end of the PHE and MOE will end the continuous coverage provision, meaning people will have to complete the renewal process – something they may not have had to do in two or more years – to keep their Medicaid coverage. Renewal time is always a time when people who are still eligible for Medicaid lose coverage because the process is complicated and confusing. The end of the continuous coverage provision will amplify that risk. States may rush to complete a backlog of renewals and understaffed state agencies may not be equipped to handle the workload. The duration of the continuous coverage provision means many enrollees won’t receive renewal information at their current address. The magnitude of the undertaking, combined with the fact that enrollees haven’t had to go through this process since before the pandemic, means that more people who are still eligible are likely to lose coverage.

Advocates have a crucial role to play to ensure that as many eligible people as possible keep their Medicaid coverage as states “unwind” from the continuous coverage provisions and begin disenrolling people. Advocates should consider the following strategies in anticipation of the end of the MOE:

1. Leverage Medicaid coalitions and expand partnerships. Medicaid coalitions – or broader safety net coalitions – should prioritize work on the end of the continuous coverage provision. Managed Care Organizations (MCOs), community health centers, food banks, and other organizations providing services to people with low incomes all have a stake in ensuring people who are eligible for Medicaid stay enrolled. All stakeholders should engage with the people they serve to encourage them to update contact information with the Medicaid agency and keep an eye out for mail from the Medicaid agency. Thinking through all avenues to reach people – social media posts and advertisements, public radio announcements, fliers in waiting rooms, or any other education and outreach strategy will be critical.
2. Engage with your state. If you aren’t already in regular communication with the state’s Medicaid office, now is the time to reach out and start a dialogue about their plans for ending the continuous coverage provision. Understanding your state’s plans and what worries them can lead to ways to collaborate to minimize coverage loss. States have been in the planning process for several months, although with the uncertainty about the timing, states are in different stages of preparedness. Key things to try to learn about your states’ plan include:

• How is your state  planning to reach people who moved since their last contact with the state;
• Will your state take the full 12 months to complete the process;
• Will your state  prioritize some groups for renewal before others;
• How is the state leveraging their partnerships with MCOs, pediatricians, and other providers;
• What are the staffing plans for handling the increase in workload;
• What are the state’s  greatest concerns;
• Does your state have an estimate of how many people will be disenrolled; and
• What data will your state track throughout the unwinding process and will it be sharing the data?

3. Track data. Once the continuous coverage provision ends, examining state Medicaid data regularly will be an important advocacy tool. Breaking down all data by race and age is also important. Key data to examine include:

• Disenrollment numbers and reasons why. Push your state to be transparent with this data if they are not already. It’s especially important to try to parse out how many people are being disenrolled for procedural reasons versus those that are known to be ineligible.
• Application numbers. While the continuous coverage provision has been in effect, application numbers have declined because churn has essentially disappeared. Now that people will be disenrolled, keeping an eye on application numbers can provide hints about how much churn may be happening.
• Wait times. Call centers and offices will likely be overwhelmed in the months following the end of the continuous enrollment provision. Long wait times are a significant barrier to completing renewal or application so it’s important to track this data and advocate with your state to minimize wait times as much as possible.

4. Lift up Medicaid enrollees’ voices. Hearing directly from Medicaid enrollees about their experiences after the continuous coverage provision ends and creating a pathway for the state Medicaid agency to hear these experiences must be part of the advocacy work. If your organization doesn’t interact directly with Medicaid enrollees, think about how to leverage existing partnerships or establish new partnerships to capture direct experiences of Medicaid enrollees with the renewal process. Knowing whether people are facing long wait times on phone lines, not receiving renewal information, being asked for excessive documentation, or facing other barriers will prioritize the advocacy asks to the state.

Advocacy engagement will be crucial for minimizing coverage loss when the continuous coverage provision ends. Using the remaining months of the PHE to deepen engagement with the state while also coordinating an “all hands on deck” approach with all stakeholders will help achieve the goal of ensuring eligible people are able to remain on Medicaid.