Unwinding of the Public Health Emergency: Medicaid Redeterminations

In March 2020, as part of COVID-19 relief legislation, Congress provided increased Medicaid funding to states. States had to meet several conditions to receive the federal funds, collectively called a Maintenance of Effort (MOE) requirement, as well as a “continuous coverage” requirement that prohibits states from terminating most Medicaid enrollees' coverage until after the public health emergency (PHE) ends, as determined by the U.S. Department of Health and Human Services.
During the PHE, Medicaid agencies can't disenroll anyone from Medicaid unless they ask to be disenrolled, move out of state, or die. Continuous coverage has allowed millions of people to stay covered without any interruption during the pandemic — and it's a major reason why there hasn't been an increase in the uninsured rate during the pandemic.
The Consolidated Appropriations Act of 2023 laid out timelines for states to return to regular Medicaid redeterminations, which were paused during the COVID-19 Public Health Emergency. States will begin redetermining all residents covered by Medicaid in February, March or April 2023, and your buildings will begin receiving Redetermination Notices all together depending upon your state's start date.?
AHCA/NCAL has shared this memo to highlight key aspects of the unwinding of the PHE and Medicaid Eligibility Redeterminations. Model guidance will be forthcoming.
Staff contact: