Millions are at risk of losing access to care and services
More than 90 million people were enrolled in Medicaid and Children’s Health Insurance Program (CHIP) as of November 2022, according to the most recent data available from Medicaid.gov. That’s a 29 percent increase in program enrollment nationwide as compared to February 2020.
But, on March 31, the continuous enrollment provision that contributed to such a drastic increase in program enrollment will no longer be in effect. This provision protected program members from disenrollment throughout the COVID-19 public health emergency (PHE). It’s estimated as many as 14 million could lose access to care and services provided by these public insurance programs during the unwinding period.
Unfortunately, of the projected millions who will lose access to benefits, many may still be eligible for services. The U.S. Department of Health and Human Services estimates close to half of those who may be unenrolled will likely still be eligible for Medicaid or CHIP. Their coverage loss will be the result of administrative churning, or the intermittent loss of benefits due to bureaucratic challenges faced by state agencies in managing high-volume waiver programs.
Those most at risk of disenrollment are people with disabilities, individuals with limited English proficiency and those who have moved since the start of the pandemic. The first two groups have long been at risk for intermittent coverage loss because information about enrollment may be difficult to access or understand. As an example, online applications may only be translated to Spanish, ignoring other potential languages program members need to fully understand requirements for renewing enrollment. Additionally, few states provide information on accessing applications in large print or Braille.
The impending enrollment changes have been forecasted for months. For almost a year, the federal government has warned the ending of the COVID-19 PHE would bring an end to the continuous enrollment provision.
State Medicaid agencies have been preparing to face this challenge head on by taking measures such as updating enrollee mailing addresses and coordinating with Medicaid managed care organizations (MCOs) to conduct outreach to those at risk of disenrollment. A Kaiser Family Foundation (KFF) analysis found nearly half of states have already begun unwinding the provision in preparation for the March 31 deadline.
The KFF report found most states plan to take a year to 14 months to complete renewals for eligible program members. The Centers for Medicare & Medicaid Services (CMS) has released guidance for states on educating program members about the unwinding of the provision and how to apply for alternative insurance options if they are no longer deemed eligible for Medicaid or CHIP.
At FEI, we stand ready to assist our state partners with the unwinding of the PHE continuous enrollment provision. Our comprehensive case management solutions are well-equipped to streamline and automate many enrollment and re-enrollment workflows, preventing administrative churn and unnecessary loss of services and support to those most in need.




