Unwinding Continuous Medicaid Coverage

The public health emergency’s end means redetermining Medicaid eligibility for millions of Texans.


In March 2020, Congress passed the Families First Coronavirus Response Act (FFCRA), allowing states to qualify for an increase in the Federal Medical Assistance Percentage (FMAP) if states kept most Medicaid enrollees on their coverage as of March 18, 2020. The FMAP increase boosts the amount of federal money Texas is receiving via its Medicaid programs, stabilizing the state’s budget while allowing enrollees to keep uninterrupted coverage during the entire public health emergency. Throughout the pandemic, continuous Medicaid coverage has served as a significant protection for roughly 5.2 million low-income Texans, as well as the state’s health care systems.

With the expiration of the COVID-19 public health emergency still uncertain, the Texas Health and Human Services Commission is preparing for the complex task of reviewing eligibility for most Texans with Medicaid coverage, the vast majority of whom are children and low-income families.

An estimated 3.7 million Medicaid members, or about 72% of those in the Medicaid program, will have their eligibility redetermined when continuous coverage ends. Of these, about 3 million people have had coverage extended because of the FFCRA’s continuous coverage provision. Those no longer eligible could be disenrolled as soon as the first day of the month after the end of the public health emergency. HHSC plans to complete all redeterminations and disenrollments within eight months. To accomplish this unprecedented effort, HHSC is adding and training new eligibility staff.

HHSC is aiming for an efficient continuous coverage unwinding that maintains coverage for eligible Texans, while prioritizing redeterminations for those most likely to be ineligible or who could qualify for other coverage, like a free or low-cost federal marketplace plan. However, advocates have expressed concerns that compressing the work of redetermining 3.7 million Medicaid enrollees in eight months could lead to thousands of eligible individuals being incorrectly disenrolled. For example, eligible enrollees who moved during the pandemic could lose Medicaid coverage if they do not respond to a renewal notice sent to their old address. Most people in this situation, the state believes, are children.

HHSC is engaging health care stakeholders in outreach efforts, while formalizing a roadmap for reviewing eligibility statuses. For now, HHSC is encouraging Medicaid members to sign up for a YourTexasBenefits account and mobile app, report any changes in contact information to ensure important notices reach them, and return renewal packets or requests for information as soon as they are received.

The Texas Hospital Association is working with health care partners to support HHSC as it initiates this monumental task and sharing important information with stakeholders to minimize the likelihood that miscommunication or procedural errors will result in Texans mistakenly losing health coverage.