Medicaid Unwinding: Your Questions Answered

When the pandemic began, Congress enacted the Families First Coronavirus Response Act (FFCRA). Designed to safeguard employees by extending paid sick and family leave, the Act also included a provision to protect Medicaid recipients from inadvertently losing coverage.

However, the Medicaid component will expire in March 2023. The end of the provision is also known as the “unwinding of Medicaid continuous enrollment” and could leave millions of beneficiaries at risk of losing this important coverage. Below we answer the most frequently asked questions about the end of the continuous enrollment provision.

Q: What is the Medicaid continuous coverage requirement? A: The continuous coverage requirement is a policy that allows people to remain eligible for Medicaid even if they experience a change in income or family size that would make them ineligible. This policy was implemented during the COVID-19 pandemic to ensure people have access to healthcare services, including testing, treatment, and vaccines.

Q: When will the continuous coverage requirement end? A: The continuous coverage requirement was originally linked to the COVID-19 Public Health Emergency (PHE), but an omnibus spending bill enacted in December 2022 sets March 31, 2023, as the end of the continuous coverage requirement, regardless of whether the PHE remains in effect.

Q: How will the end of the continuous coverage requirement affect Medicaid? A: States need to review the eligibility of every person enrolled in Medicaid to determine if they are still eligible. This process is called “unwinding” and states have 12 months to initiate eligibility reviews of all their enrollees. Most states will spread their work over 12 months, but each state is determining its own timeline.

Q: What guidelines must states follow during the unwinding process? A: States must complete a full eligibility review using an enrollee’s current information and through electronic data sources before sending a renewal form. Enrollees have at least 30 days to complete and return renewal forms to the state. Those who do not complete and return the renewal form could lose their Medicaid coverage.

Q: What challenges could Medicaid enrollees face during the unwinding process? A: Millions of enrollees could lose their Medicaid coverage during the unwinding process for two reasons: eligibility or procedural. Eligibility issues arise when enrollees are no longer eligible for Medicaid due to changes in their circumstances. Procedural issues arise due to administrative errors or barriers enrollees face during the renewal process.

Q: What should people enrolled in Medicaid do to stay covered? A: People enrolled in Medicaid should ensure their state Medicaid agency has their current mailing address and phone number. States are currently mailing important notices and may begin sending renewal forms in the coming months.

Q: What should people do if they lose their Medicaid coverage during this process? A: People who lose Medicaid for procedural reasons have 90 days to contact the Medicaid agency and submit their renewal paperwork. If they’re still eligible for Medicaid, the state must restore their coverage back to the date their coverage ended.

People who lose coverage due to eligibility issues may qualify for coverage through the marketplace, Medicare, or job-based coverage. For more information about your options, contact our office today.