Medicaid public health emergency mitigation policies affecting the elderly and people with disabilities: Findings from a 50-state survey

Medicaid remains an important source of coverage for seniors and people with disabilities, often providing access to long-term services and supports (LTSS) not covered by Medicare or private coverage. Provisions in the Families First Response Act (FFCRA) require states to provide continued coverage to Medicaid enrollees through the end of the month in which the COVID-19 public health emergency (PHE) ends in order to receive enhanced federal funding. PHE is currently in effect until July 15, 2022, and is expected to be extended until at least October 13, 2022. Centers for Medicare and Medicaid Services guidance recognizes that returning to normal operations when PHE ends will require planning to avoid inappropriate loss of coverage as states review eligibility for large volumes of enrollees.

This publication summary describes anticipated enrollment changes in the aging or disability-based (“non-MAGI”) pathways after the end of PHE, state enrollment and renewal policies for non-MAGI groups beginning January 1, 2022, and state plans for resume normal operations when PHE ends. These pathways are known as “non-MAGI” pathways because they do not use the Modified Adjusted Gross Income (MAGI) financial methodology that applies to eligibility for low-income pregnant women, parents, and children. Data were collected from March to May 2022 in the KFF survey of state Medicaid eligibility officials. Overall, 50 states and the District of Columbia responded to the survey, although response rates for specific questions varied. Key findings include the following:

  • Most states reported that non-MAGI enrollments increased during PHE COVID-19, and most states anticipate loss of coverage at the end of PHE. Of the 37 states that responded, states most often cited change in income, followed by returned mail or inability to contact the enrollee as the top reasons for projected coverage losses. An average of 10 percent of non-MAGI enrollees are expected to lose coverage at the end of PHE (14 states respond).
  • Staff shortages and enrollee confusion were the most frequently identified issues expected to affect non-MAGI enrollees as states return to normal operations when PHE ends.
  • Most states (23 of 35 that responded) currently renew eligibility for a small portion (<25%) of non-MAGI enrollees on an ex parte basis (without requesting information from the enrollee). However, most states have adopted at least one strategy to increase the share of ex parte renewals including relying on SNAP data without performing a separate Medicaid determination (12 states), automating data checks (12 states), and expanding the number and type of electronic data sources used (11 countries).
  • Most states are planning to partner with other entities, such as health plans, providers, or community-based organizations, to provide information and/or assistance to seniors and people with disabilities who need to renew Medicaid eligibility. or switching to other coverage (such as Medicare or Marketplace coverage) after PHE ends.

Seeing PHE end, ensuring that eligible people remain enrolled or successfully transition to other coverage can help minimize gaps in coverage. This is particularly important for older people and people with disabilities, many of whom have chronic health needs and rely on long-term services and supports to meet day-to-day needs. Historically, people who are enrolled in Medicaid on age- or disability-based pathways experience lower dropout rates than children and non-elderly adults enrolled on the basis of low income alone, because they have more unlikely to experience changes in income or other influencing factors. their continued eligibility for Medicaid. However, at the end of PHE, when millions of enrollees will have to complete a renewal, staffing shortages and enrollee confusion about how to navigate the process could increase the risks of losing coverage. State policies to simplify eligibility and enrollment, such as increasing the share of non-MAGI renewals done ex parte, can minimize staff burden and promote continuity of coverage.

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