May 25, 2022

CMS and State Preparations for Medicaid Unwinding

BY Ruth

Last week, we learned that the Public Health Emergency (PHE) will likely be extended until at least mid-October. An official extension will not be announced until July but HHS promised 60 days notice to states and that timeframe passed last week. Even though there is now a longer runway, CMS and states are continuing to prepare for the unwinding of PHE Medicaid practices and the eventual return to regular operations across Medicaid programs. The federal government has eased rules to prevent people with Medicaid from losing their health coverage with a continuous enrollment requirement. When the PHE ends, states will be required to restart Medicaid eligibility reviews. According to Kaiser Health Foundation (KFF) analysis, most older adults are expected to remain eligible. The primary concern is that older adults may not respond to Medicaid redetermination and renewal mailings and will experience a loss of coverage and then have to re-enroll.

States will be handling messaging to beneficiaries in two stages, with Phase 1 beginning now. The estimate is that as many as 12% of Medicaid beneficiaries have an incorrect address on file and won’t receive reenrollment notices. The current focus is encouraging beneficiaries to update their contact information. To reach the most people, states are embarking on coordinated plans to reach all beneficiaries by engaging with trusted ambassadors. LeadingAge members can be on the look out for opportunities to be a trusted ambassador in their states. Phase 2 of beneficiary communication and outreach will launch when the end of the PHE has been announced. At this point, letters will let older adults know if they need to complete a renewal form to see if they still qualify. We are hoping by this time that that the FCC will have responded to the formal request from HHS Secretary Becerra and CMS Administrator Brooks-LaSure on whether certain text messages and automated, pre-recorded telephone calls to individuals’ cell phones are permissible as part of a multi-pronged outreach approach. In Phase 2, states will also restart yearly Medicaid eligibility reviews. This means states will use information that they have to decide if Medicaid beneficiaries still qualify. If a state needs more to make a coverage decision, they’ll send a renewal letter in the mail. Older adults will then need to complete the renewal form (if they get one.)

States will be launching unwinding plans and dashboards for legislatures, advocates, and providers. Medicaid and state specific information can be found here. It’s a good idea to start interfacing with your State Medicaid agency and to look for opportunities to be part of the stakeholder process on behalf of older adults, and in regard to which PHE flexibilities have worked and should remain. For more information on the potential impacts of the PHE unwinding for older adult Medicaid beneficiaries, what Medicaid leaders are doing to prepare, and how LeadingAge members can partner and advocate with their states, please contact Meredith Chillemi.