When the Public Health Emergency ends, children may suffer more
The COVID-19 pandemic has affected all of us in immeasurable ways. It’s revealed gaps in our social safety nets, and created and exposed countless vulnerabilities.
To mitigate disparities produced and uncovered by the pandemic, the federal government mandated those receiving Medicaid or Children’s Health Insurance Program (CHIP) benefits cannot lose coverage during the designated Public Health Emergency (PHE). While this continuous enrollment authorization allowed more people to obtain and retain vital healthcare coverage, its potential unwinding in the next few months has spurred many questions. Particularly, how will this change affect one of our most vulnerable populations—children?
From February 2020 to September 2022, total Medicaid and CHIP enrollment increased by 20.2 million or more than 28 percent, bringing total Medicaid and CHIP enrollment to more than 90 million people, about 45 percent of which are children. Perhaps the biggest driver of this change was the continuous enrollment authorization.
As of December 2022, the Medicaid continuous enrollment requirement is no longer tied to the PHE and all states are required to resume pre-pandemic Medicaid eligibility determination on April 1, 2023. The unwinding of the Medicaid continuous enrollment requirement is projected to cause the single largest health coverage shift since the Affordable Care Act was introduced. Some projections estimate between five and 14 million people could lose their coverage as a result of this transition.
Barriers to Re-Entry
While the barriers adults will face in this transition are numerous and varied, perhaps the biggest vulnerability children face is their reliance on adults to make informed decisions on their behalf. This presents an especially difficult challenge for the 41.3 million children currently receiving Medicaid or CHIP coverage. In other words, concerns about continued eligibility are not unique to children, but there is a “hidden and ongoing secondary tragedy” affecting them in a unique way.
A study published in December 2021 by the American Association of Pediatrics found approximately one in 500 children in the U.S. has experienced COVID-19-associated orphanhood or death of a grandparent caregiver. The loss of a parent or caregiver can change eligibility based on income or household size, but the loss of both can remove a child from their household entirely.
Foster children are covered by Medicaid, but the pandemic has added a new population of orphaned children to an already overburdened system. While these children will not lose their eligibility during the return to normal operations, they may become part of the 6.8 million enrollees who are projected to lose coverage as a result of administrative churning.
On top of that, while Medicaid functions as a partnership between federal and state entities, much of the process for returning to normal enrollment practices after the PHE ends will fall to the states, likely resulting in confusing or conflicting information. The Centers for Medicare & Medicaid Services (CMS) is instructing states to make plans for the upcoming eligibility and enrollment work, but the agency is not requiring these plans be complete before the unwinding period begins, nor is it requiring plans to be shared publicly. This leaves eligible adults without public information available at a disadvantage, and their children even more so.




