New! Tips for Advocates on Preparing for Unwinding of the PHE Continuous Eligibility Provision

[Editor’s Note: A new version of our Tips and Best Practices for Unwinding the Medicaid Continuous Coverage Protection can be found here.]

Although the end of the public health emergency (PHE) remains a moving target, it’s not too early to start planning for phasing out the continuous eligibility maintenance of effort provision and the eventual return to routine eligibility and enrollment operations. Earlier this month, we hosted a webinar with colleagues from the Center on Budget and Policy Priorities focused on eligibility and enrollment post-PHE. Next week, on September 8, we will hear from state-based groups who are working together with partners to engage in their state’s planning process. Today, we are posting Tips for Advocates in engaging with their state in planning for the end of the PHE.

There are many actions states can take now and in the coming months to be better prepared for what is almost certain to be a chaotic time for Medicaid eligibility operations. Our end goal is clear; we are laser-focused on making sure that all eligible children and families retain the health coverage they need without a gap.

We only need to look to Utah’s recent CHIP experience to understand the potential threat to the continuity of coverage for children. In May, 41 percent of CHIP enrollees lost coverage after the state resumed its renewal process, which had been suspended since the beginning of the PHE. Yet, state officials believe that perhaps only 700 of the more than 6,200 children who lost coverage were disenrolled because they were no longer eligible. There’s a story behind how and why this happened but let’s keep our focus on preventing similar experiences in other states, starting with steps states can take now to be better prepared for the unwinding.

Increasing the Rate of Renewals Successfully Conducted through Ex Parte Processes

States are required to first attempt to renew Medicaid eligibility using electronic data sources to verify eligibility before asking enrollees to return a form or paper verifications. CMS has directed states to continue processing ex parte renewals even though coverage cannot be terminated until after the PHE ends. The more successful this process is, the smaller the backlog of pending actions at the end of the PHE. States can increase ex parte rates now by expanding data sources used to verify eligibility and analyzing unsuccessful matches to identify system programming to improve the match rate.

Updating Mailing Addresses

At the top of the list for early work is updating mailing addresses. Returned mail disrupts Medicaid enrollment in the best of times with some states automatically terminating coverage after receiving a single piece of returned mail. The problem will be more pronounced post-PHE given that housing instability has accelerated during the pandemic. Look at our tips on the many ways for states to update contact information and for advocates and other stakeholders to support the effort.

Boosting Communications and Consumer Assistance

By the end of the PHE, it will have been two years or more since Medicaid enrollees were required to renew their eligibility. It will be important for states to communicate with enrollees and all stakeholders, including eligibility workers, providers, managed care plans, consumer groups, and advocates, about upcoming changes as we get closer to the end of the PHE. Once the state begins to restart renewals, there will be a greater need for consumer assistance. So, states should be planning to right-size consumer assistance and balance the timeline for returning to normal operations with the size of the backlog and capacity of eligibility staff to manage the workload.

You’ll find these and other action steps in our new Tips for Advocates. And stay tuned for more blogs on the unwinding, including what CMS is telling states about ensuring continuity of coverage and preventing inappropriate terminations.