As part of the year end omnibus spending package passed by Congress in December, there was a provision in the law which brought some certainty to the end of the Medicaid continuous coverage requirement that was tied to the end of the Public Health Emergency (PHE). When the COVID-19 pandemic began, one of the early relief packages passed by Congress included a provision which required states to maintain Medicaid coverage for all enrollees as long as the PHE continued. In the omnibus spending package, a provision in the law set the end of the continuous coverage requirement for April 1.
Starting April 1, 2023, states will have 12 months to initiate their redetermination process for all Medicaid enrollees. The increased federal funding which states were receiving for maintaining continuous coverage through Medicaid will slowly be phased out which will allow states to conduct the redetermination effort in a more deliberative way which will hopefully reduce the number of enrollees who are disenrolled due to administrative errors. Finally, the new law does provide additional oversight for CMS to ensure that states are conducting redeterminations in a transparent manner.
At the end of last week, CMS released new guidance on the unwinding of the Medicaid continuous coverage requirement.