Partnering With Medicaid to Successfully Unwind the Continuous Eligibility Requirements

Dear colleagues:

Grateful thanks for your continued work on issues of shared interest and concern for Medicaid Directors and the millions of members whom they serve.

As we migrate towards the eventual sunset of the federal public health emergency, Medicaid leaders are appropriately focusing on one of the most important aspects of resuming more historically typical operations – the “unwinding” of pandemic continuous eligibility requirements. In this effort, directors and their teams are prioritizing the following:

• observing all normal procedural requirements for eligibility redeterminations;
• paying special attention to people who are the most likely to be disconnected from the health care system, including older adults, people of color and people with disabilities; and
• compliance with all federal requirements for unwinding.

We are grateful to our federal partners for continuing to release successive pieces of guidance that are equipping states as they move forward. Of particular note is that on Friday, January 27, the Center for Medicaid and CHIP Services (CMCS) released guidance that clarifies key policy questions related to the unwinding.

In particular, in order to support all those currently enrolled in Medicaid and to continue to qualify for enhanced federal financial match, states will need to:

• comply with all federal requirements surrounding redeterminations of Medicaid eligibility;
• attempt to update members’ contact information using sources such as the National Change of Address (NCOA) database, MCOs, contact with members, and state health and human services agencies; and
• make a good faith effort to contact members using at least two additional modalities (including telephone, email, text, communication through an online portal, or other electronic means) before disenrolling on the basis of returned mail.

Further, the guidance provides detail on CMS’ oversight role in this process, including new enforcement authorities given to CMS by Congress. Related, CMCS’ sister agency CCIIO announced a new special enrollment period for states that use the federal marketplace platform, which is welcomed by Medicaid Directors as they seek to support transition of people who are no longer eligible for Medicaid to marketplace coverage.

Now that we have greater clarity around timing and process, know that states have been carefully preparing their “unwinding” plans for many months, and are now actively on deck in beginning to implement them, how can you help? You can:

• continue to support state folks by reminding Medicaid members to update their contact information;
• acknowledge the importance and scale of this effort, but also that it represents a return to normal eligibility processes that states have handled for years; and
• support connections between Medicaid staff, plans, assisters and marketplaces and employers – something on which CCIIO is appropriately focused.

We will continue to communicate about how this work is rolling out in future messages, and are thankful for all that you are doing to link arms.

In partnership,

Kate