The Latest on Medicaid Coverage and the COVID-19 Public Health Emergency

Disenrollment a danger for many Texans – including those who will still be eligible for coverage


The federal COVID-19 public health emergency (PHE), active since late January 2020, was renewed on Jan. 11 for another 90 days. It’s widely expected that this latest extension, running through April 11, may be the last. As the end of the PHE became an imminent expectation for much of 2022, one of the biggest implications revolved around continuous Medicaid coverage allowed while the PHE was in effect. However, federal end-of-year legislation recently made the end of the PHE no longer a factor in determining the fate of Medicaid continuous coverage and the enhanced Federal Medical Assistance Percentage (FMAP) matching payments the state receives for Medicaid.

For hospitals and providers, alerting patients about the end of continuous coverage is still important – perhaps even more so due to the federal legislation. Now, if states choose, they’ll be allowed to disenroll freshly ineligible Medicaid beneficiaries as soon as April 1 – even though the latest extension of the PHE will still be in effect at that time. Disenrollment carries particularly devastating consequences in Texas, the state that already had the nation’s highest uninsured rate even before the pandemic.

No longer tied to the PHE

Previously, while the PHE remained in effect, to receive an enhanced FMAP states had to allow Medicaid recipients to retain continuous coverage through the calendar month that the PHE ends. That continuous-coverage provision has ensured that around 5.2 million low-income Texans have stayed enrolled in Medicaid since the pandemic began, including pregnant women, children and residents of long-term care facilities.

But the end-of-year omnibus bill de-links the Medicaid continuous coverage requirement from the PHE, ending that protection on March 31. Additionally, the bill phases down the enhanced FMAP, which will end on Dec. 31. As part of the unwinding process, the Texas Health and Human Services Commission (HHSC) is planning to redetermine eligibility for up to 2.7 million current Medicaid enrollees, verifying that they meet certain requirements (such as income level) to remain enrolled. The state is attempting to complete that process in three months.

Help patients stay enrolled

CMS guidance explains that, with the newly established March end date, states can begin renewals in February, March, or April and have 14 months to complete their unwinding renewals. Because of that federal action, enrollees who are no longer eligible can be disenrolled as soon as April 1. HHSC is planning to begin renewals April 1.

However, that impending process threatens to disenroll still-eligible beneficiaries who have not updated their contact information if it changed during the PHE, or don’t submit a completed renewal application on time. To better serve these beneficiaries, HHSC has hired a large number of eligibility workers to speed up paperwork processing and is rolling out technology improvements to address long phone wait times for enrollees trying to update their contact information.

To help hospitals and others prepare themselves and patients for this transition, HHSC has published an End of Coverage Ambassador Toolkit, which contains resources for providers, health care advocates and insurers to let patients know about the upcoming Medicaid continuous coverage expiration and unwinding process. The toolkit contains flyers, information sheets and FAQs to spread the word to Medicaid recipients about the importance of updating their contact information with HHSC to stay enrolled.

THA and other stakeholders are waiting to hear further updates from HHSC on its unwinding plan and/or changes to the toolkit and messaging to share with patients.