Public Health Emergency Ensures Medicaid Coverage – But For How Long?


When the COVID-19 pandemic first took hold of the nation, legislation quickly passed that has allowed most Medicaid enrollees to maintain coverage during the ongoing public health emergency. The federal Families First Coronavirus Response Act granted states an increase in federal Medicaid dollars as long as they paused disenrolling anyone from their Medicaid programs starting in March 2020. With the boost in Medicaid dollars Texas received, the state’s budget was stabilized, and Medicaid enrollees were granted uninterrupted coverage during the PHE.

This continuous Medicaid coverage has safeguarded the state’s health care system throughout the pandemic and provided significant protection for millions of low-income Texans. Without routine disenrollments occurring, the state’s Medicaid enrollment grew from about 3.8 million pre-pandemic to 5.1 million in November 2021. While many providers and patients have been bracing for the official end of the public health emergency, the U.S. Department of Health and Human Services has promised to give 60 days’ notice. And right now, it is projected that the public health emergency will be in place through mid-October, if not longer. But once the PHE officially expires, states will begin the substantial task of redetermining Medicaid eligibility for most enrollees.

In March, the Centers for Medicare & Medicaid Services issued a guidance letter to state health officials on the redetermination process, which involves checking whether each enrollee still meets Medicaid eligibility criteria based on factors like family income, age, Texas residency, or pregnancy status. According to the guidance, states may initiate redetermination efforts two months prior to the 12-month unwinding period, with 14 months total to complete all renewals, post-enrollment verifications, and redeterminations based on changes in an enrollee’s circumstances. For those found no longer eligible, coverage can terminate beginning the first day of the next month following the end of the PHE.

The Texas Hospital Association and health care partners have highlighted to the Texas Health and Human Services Commission the impact ending continuous Medicaid coverage will have on the roughly 3.7 million Texans requiring eligibility redeterminations, about 3 million of which maintained coverage under the PHE-related continuous coverage provision. THA and other stakeholder groups asked HHSC to ensure enrollees – whose address, employment, or contact information may have changed during the pandemic – have ample time to be reached and don’t lose coverage because of an administrative error. THA also suggests allowing individuals who have initiated the renewal process to remain enrolled until their case is processed.

With millions of Texans dependent on Medicaid coverage for continued access to care, it’s crucial they know about the steps needed to avoid losing benefits. Providers, health plans, and advocates can start sharing information with the health care community and Medicaid participants on the importance of promptly responding to renewal or information requests from HHSC to avoid interruptions in coverage. HHSC recently published their End of Continuous Medicaid Coverage Ambassador Toolkit, with key messaging and an FAQ to assist with informing Medicaid participants of the upcoming unwinding process. Enrollees should sign up for an account at or on the Your Texas Benefits mobile app, which allows individuals to view their account information, update contact information, respond to requests from HHSC and submit their renewal packets sent by the agency. If someone doesn’t want to set up a Your Texas Benefits account, they may also submit information by mail or fax, or by dialing 211.

To ensure HHSC notices are received and correct information is on file, it is imperative Medicaid enrollees report any changes in their contact information, such as a change of address, if they’ve had a baby or if there’s been a change in employment. Once renewal packets are received, they must be completed and submitted as soon as possible to avoid gaps in coverage or losing it altogether. For those who are found to not be eligible, the agency will evaluate their eligibility for other programs, such as CHIP or Healthy Texas Women, and an appeals process will be available as well.

While HHSC works on the monumental task by hiring and training new eligibility staff, the health care community can help out by engaging stakeholders in outreach efforts to minimize the likelihood that miscommunication or procedural errors will result in Texans mistakenly losing vital health coverage. Providers are encouraged to begin talking now to their Medicaid patients about the potential end in coverage and help steer them toward other coverage options, including the Federal Marketplace. Coverage is critical to all Texans, and THA will continue to push for expansion and help ensure enrollees have the tools they need to access health care in Texas.

Originally published by the Houston Medical Journal.
June 16, 2022