Pandemic-Era Medicaid Protections Set to Wind Down
On January 26, 2023, public health policy experts and state agencies across the U.S. prepared for a seismic shift in healthcare access as provisions from the Consolidated Appropriations Act of 2023 came into sharper focus. Among its most consequential components was the formal end to the federal moratorium on Medicaid eligibility redeterminations—a policy enacted in March 2020 to ensure continuous coverage for beneficiaries during the COVID-19 public health emergency.
For nearly three years, this continuous enrollment requirement meant that Medicaid enrollees could maintain their health coverage without undergoing annual eligibility checks. However, the new federal law set a clear timeline for states to begin phased redeterminations starting in April 2023, with preparation and implementation efforts accelerating by late January.
Background: Continuous Coverage and Its Impact
Under the Families First Coronavirus Response Act (FFCRA) of 2020, states received enhanced federal Medicaid funding in exchange for a critical condition: they could not disenroll beneficiaries during the declared public health emergency. This move protected vulnerable populations during a period of widespread job loss, housing instability, and health uncertainty.
As a result, Medicaid enrollment ballooned to record highs, covering more than 90 million Americans by the end of 2022. However, this growth came with growing concerns about “coverage cliffs” once the moratorium was lifted—wherein millions might be dropped from Medicaid rolls if they no longer met eligibility requirements but failed to navigate the renewal process.
The Redetermination Process and State Responsibilities
The Consolidated Appropriations Act decoupled Medicaid continuous enrollment from the public health emergency and outlined a 12-month unwinding period starting April 1, 2023. States were given flexibility in structuring the redetermination process but were also required to:
- Develop outreach strategies to contact enrollees and verify their eligibility.
- Update outdated contact information to avoid administrative disenrollments.
- Use data-driven methods to automate renewals where possible.
- Report regularly to CMS (Centers for Medicare & Medicaid Services) on progress and outcomes.
Health policy experts emphasized that communication would be paramount. Millions of individuals who moved residences, changed phone numbers, or lacked internet access during the pandemic might miss critical renewal notices—potentially losing coverage despite remaining eligible.
Populations Most at Risk
Several groups are at heightened risk of losing coverage during the redetermination process:
- Children in low-income households, who often receive care through Medicaid or the Children’s Health Insurance Program (CHIP).
- Working adults whose incomes fluctuate or fall just above state eligibility thresholds.
- Non-English speakers or people with limited literacy, who may struggle to interpret renewal requirements.
- Disabled or chronically ill beneficiaries, for whom even short-term gaps in coverage could lead to adverse health outcomes.
To address these concerns, advocacy organizations have called for states to collaborate with community-based organizations, employ multilingual outreach campaigns, and simplify renewal procedures wherever possible.
A National Challenge with Far-Reaching Implications
The resumption of Medicaid eligibility reviews represents one of the most significant public health administrative transitions since the pandemic began. While it marks a return to normal program operations, it also poses serious risks of coverage loss for vulnerable populations, potentially leading to increased emergency room visits, worsened health conditions, and financial strain on safety-net providers.
State Medicaid directors have been racing to expand call center capacity, streamline renewal forms, and train caseworkers to handle the impending deluge of eligibility checks. Meanwhile, federal officials have urged a cautious, data-informed approach to avoid unnecessary disruptions in healthcare access.
As of late January 2023, the nation stood on the edge of a complex health coverage cliff, with the next few months critical in determining how many Americans retain the care they depend on.
Source:
PCG Health Policy – Medicaid Policy Developments
