The End of the COVID-19 Public Health Emergency Will Substantially Impact Medicaid Beneficiaries

Under the Public Health Service Act, Pub.L. 78–410,  when the Department of Health and Human Services (HHS) concludes that a disease or disorder presents a public health emergency,  the agency may issue a declaration announcing that a public emergency exists.  On January 31, 2020, HHS issued a declaration announcing that a public emergency existed based upon the pandemic caused by Coronavirus Disease 2019 (COVID-19). This declaration has been renewed continuously since it was issued, with the latest renewal occurring on October 13, 2022.

The Families First Coronavirus Response Act (FFCRA), Pub.L. 116–127, was signed into law on March 18, 2020. FFCRA. is an Act of Congress meant to respond to the economic impacts of the ongoing COVID-19 pandemic. FFCRA contained provisions encouraging states to permit Medicaid and Children’s Health Insurance enrollees to retain benefits during the public health emergency. Under the FFCRA, states that allowed Medicaid beneficiaries who were enrolled on March 20, 2020 to remain continuously covered until the COVID-19 Public Health Emergency ended received an increase by 6.2 percentage points in their Medicaid match rates.  Every state took up that offer, and today, an estimated 18.7 million more people are enrolled in Medicaid than would have been the case without this provision. In fact, because of this continuous enrollment provision and other laws, HHS reported that the uninsured rate among U.S. residents reached an all time low of 8% in the first quarter of 2022.

If the public health emergency declaration is not extended, the Public Health Emergency declaration based upon the COVID-19 pandemic will soon end, terminating on January 11, 2023.

At the end of the Public Health Emergency, many Medicaid enrollees will become ineligible for benefits. HHS estimated that 17.4% of Medicaid and Children’s Health Insurance enrollees (approximately 15 million people) will leave the program, including 8.2 million Medicaid enrollees because they no longer qualify.  In addition, others will lose benefits due to “administrative churning,” defined as “the loss of Medicaid coverage despite ongoing eligibility, which can occur if enrollees have difficulty navigating the renewal process, states are unable to contact enrollees due to a change of address, or other administrative hurdles.”   The effect of what HHS describes as “administrative churning” will essentially double the number of enrollees who lose Medicaid benefits. Also, beneficiaries will again become subject to periodic reassessments, called redeterminations, to determine whether they continue to qualify for benefits. These reassessments will also identify many Medicaid beneficiaries as presently ineligible for benefits.

Thus, as a result of the above, when the public health emergency ends, it is expected that a substantial number of enrollees who presently qualify for Medicaid benefits will lose coverage permanently or temporarily based upon factors unrelated to actual need.

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