Looking Ahead: The End of the COVID-19 Medicaid Continuous Coverage Requirement
February 2023

By Atyya Chaudhry, Senior Program Manager, Health Systems Transformation, Association for Maternal & Child Health Programs (AMCHP)

In March 2020, shortly after the federal Public Health Emergency (PHE) was declared to respond to the COVID-19 pandemic, the Families First Coronavirus Response Act (FFCRA) was signed into law to facilitate the nation’s response to the PHE. One important provision in FFCRA for states was a 6.2 percent increase in their federal matching fund rate if their Medicaid programs met specific Maintenance of Effort requirements, which included continuous enrollment of all Medicaid beneficiaries through the end of the PHE. As a result, Medicaid enrollment over the past two years has skyrocketed. Data from January 2023 show that total Medicaid/Children’s Health Insurance Program enrollment grew to nearly 91 million during the PHE. This number represents an increase of nearly 20 million from enrollment in February 2020.

More recently, the end-of-year federal spending bill, signed into law on December 29, 2022, included a provision for the Medicaid continuous enrollment requirement to end on March 31, 2023.

As such, all Medicaid enrollees, including children, must be redetermined for eligibility within a one-year period, beginning April 1, 2023. Concurrently, the enhanced federal matching funds will be phased down through December 2023.

The Kaiser Family Foundation estimates that anywhere between 5 and 14 million Medicaid beneficiaries could lose coverage during the year-long redetermination process. Maternal and child health (MCH) advocates have two other concerns with the redetermination process.

  • Enrollees who remain eligible for Medicaid may lose coverage if they do not know they need to notify Medicaid if their contact information is outdated or if they don’t know how to contact Medicaid.
  • The unwinding of the continuous coverage requirement will also place a significant burden on understaffed state Medicaid agencies. These agencies likely will face challenges such as case backlogs, clerical errors, and other administrative-related issues.

The bottom line is if the redetermination process is not conducted smoothly, it could trigger a Medicaid coverage crisis for millions of enrollees, including women, children, and families.

With a firm date to begin Medicaid redeterminations and the risk of disruptions or loss of coverage, it is more important than ever for Title V MCH programs to plan and prepare for the year-long process. Several Title V MCH programs are meeting regularly with their state Medicaid programs, gathering data on possible disruptions in coverage, and they are disseminating information and communicating with families during care coordination meetings. They are also establishing redetermination advisory committees.

MCH advocates are encouraging outreach to families, particularly on the need to update Medicaid contact information. The Centers for Medicare & Medicaid Services has published a Communications Toolkit for states, and several organizations have developed social media materials that states can use or adapt, including Organizing for Outreach and Community Catalyst.

AMCHP will continue to closely monitor this issue. Our fact sheet here on this topic includes a helpful list of strategies and additional resources. In March 2023, Georgetown University Center for Children and Families experts will join AMCHP for a webinar on the unwinding process. If you have questions about the unwinding of the Medicaid continuous coverage requirement or would like to share your state’s strategies and materials for helping the people you serve, please get in touch with Atyya Chaudhry at achaudhry@amchp.org.