HHS Secretary Becerra has committed to giving states at least 60 days of advance notice before the end of the PHE, so if this current renewal is the last, notice would be issued by August 14, 2022 and the PHE would conclude in mid-October. However, many, including the National Association of State Medicaid Directors, believe that HHS will issue at least one additional PHE renewal, based on public health and political grounds, meaning that the PHE would be extended into 2023.

Despite the uncertain timeline, PHE unwinding considerations and preparations in the Medicaid space are top of mind for policymakers and advocates. On July 27, 2020, MACPAC held a special meeting focusing on challenges that state Medicaid programs may face when the Covid-19 Public Health Emergency (PHE) ends and Medicaid eligibility redeterminations commence.  MACPAC commissioners have been closely following CMS and state preparations for unwinding the PHE continuous coverage requirement. In particular, the Commission is focused on the potential risk of eligible individuals inappropriately losing coverage as states resume redeterminations, as well as state administrative and system capacity to handle redeterminations. Commissioners made comments during the MACPAC meeting, stating their interest in the following areas:

• Ex parte renewals being used by states as much as possible to support less churn during unwinding. (Ex parte is any process that allows renewal of Medicaid coverage without the individual completing a form or providing documentation. An example would be using SNAP information to verify Medicaid eligibility.)
• States working with Managed Care Organizations to help beneficiaries retain Medicaid coverage
• Disenrollment data during unwinding to be available in real time, so that states have the opportunity to pivot and help beneficiaries retain coverage.
• CMS soliciting provider feedback via national associations during unwinding as a key piece to the puzzle to supplement hard data.

The Center on Budget and Policy Priorities, a group that focuses on policy solutions for low-income people, also recently offered insights on how States Can Reduce Medicaid’s Administrative Burdens to Advance Health and Racial Equity. The authors looked at the obstacles people face when they are eligible for Medicaid but can’t enroll, or when they experience gaps in coverage due to administrative burdens, both of which disproportionately impact people of color. Many states have failed to fully implement the ACA’s access requirements, and states must act to reduce Medicaid administrative burdens with the following actions:

• Simplify and shorten forms
• Allow for managing and submitting documents online
• Fund outreach and enrollment assistance
• Increase communication with texting, electronic notices and call centers
• Provide 12 months of continuous enrollment
• Reduce verification requests by coordinating with other programs and increasing ex parte renewals

The Center on Budget and Policy Priorities also calls on CMS, in its role funding and overseeing Medicaid, to provide guidance on best practices, policy clarity, and state accountability to make sure administrative barriers are dismantled to ensure eligible people have access to the program.

A concerted effort to streamline Medicaid redeterminations, during unwinding and beyond, is vital to increasing the ability of the eligible older adults that LeadingAge members serve to participate in Medicaid coverage and the services they need to age in community with Home and Community-Based Services.