HHS Secretary Becerra has declared that the COVID-19 public health emergency is extended for another 90 days through January 11, 2023. This means that February 1, 2023, is the earliest that the Medicaid continuous coverage protection would be lifted and states could begin to disenroll people after completing a full renewal and review of ongoing eligibility based on current circumstances. The enhanced Medicaid match of 6.2% points (and CHIP increased match of 4.34% points) will both remain in effect through the end of March 2023. States are only bound to the continuous enrollment provisions if they accept the enhanced match – and to date, all of them continue to do so.

As a reminder, the Biden administration promised to give states and stakeholders 60 days advance notice before the end of the PHE. For the next go around that date would be November 12^th, which falls over the long Veteran’s Day holiday weekend. So, if the administration does not give notice by November 12^th, we would expect the PHE to be extended again in January until early April.

It’s possible that Congress could take action to establish a date certain for lifting the Medicaid continuous coverage protection by delinking it from the PHE when they meet in a lame-duck session after the election. Otherwise, this call remains in the hands of the Biden Administration.

This graphic provides a visual of key dates in place if the PHE ends in January. Is that likely to happen? I am not making any predictions or taking any bets. Like the rest of you, I’ll be waiting for the next trigger date in November to find out.