Announcement of End of Medicaid Continuous Coverage Requirement

At the beginning of the COVID Public Health Emergency (PHE), the federal government suspended Medicaid re-determinations and ordered states to maintain continuous Medicaid coverage for all currently enrolled beneficiaries through the end of the emergency.?

?The federal Consolidated Appropriations Act of 2023 ends the PHE and consequently ends the Medicaid continuous coverage requirement that has been in place since March 2020. Medicaid eligibility systems and processes are being readied for restarting Medicaid re-determinations, and returning to pre-pandemic regular Medicaid program rules and operations (the “Unwind”), effective April 1, 2023. Based on the Federal mandate, states will be required to “unwind” these coverages through a mass re-determination process.?Commentary from multiple sources says it is inevitable that a large number of people (5-14 million by one estimate – Kaiser Family Foundation) will lose coverage.?Obviously, this will be chaotic as beneficiaries are contacted, re-enrollment is processed, and former beneficiaries and their providers have to contend with the transition.?The timeline for the process could take up to 14 months.?According to several home care associations we checked with, states have been announcing their specific plans.???

?For long-term care providers (home care and some IDD providers depending on the client’s program), this means that some of their clients may lose coverage temporarily or permanently.?Consumers may be non-responsive to the re-determination notifications, or may not re-qualify because of income/asset changes.?The back-stop for many will be the state insurance marketplaces, but those plans typically don’t cover long term custodial care.?For legal reasons, providers will not be able to immediately discharge these clients.?Each state has a process that must be followed prior to discharge, that can take up to 2 weeks.?During that time there is no payer so services must be provided with no reimbursement.?And typically, agencies will follow their moral compass and not “turn their clients out in the cold”, so the 2 weeks might continue longer.?

?Sandata Revenue Cycle Management guidance to agencies is firstly, to be engaged with and monitor your state process as published and updated by your state Medicaid department and your state Home Care / IDD Association.?Secondly and most importantly, at least starting April 1, be very vigilant about checking for eligibility, to ensure you learn immediately if/when beneficiaries lose their Medicaid certification.?

?Eligibility should be checked on the 1st and 15th of each month (not before or after) as this is when eligibility records are updated.?Check the state databases, vs MCO databases, as there might be a lag in MCO databases being updated.?This process should be continued for all clients beyond the client’s termination date, as it would also advise the agency when the client re-certifies if the eligibility loss was temporary, and in the case of managed care, if there is a different payer than before.?Of course, coordinate with the client on the status of their re-determination process.?