What Does the End of Continuous Enrollment Mean for Your Medicaid Clients?

How should you manage the end of the continuous enrollment provision for Medicaid?
1 May 2023

What Does the End of Continuous Enrollment Mean for Your Medicaid Clients?

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When you work with Medicaid and Medicare, one of the most important aspects of your job is awareness of the enrollment periods. Particularly when dealing with programs that can shift eligibility standards, enrollment periods will always prompt questions and concerns from your clients, and you have to be ready.

Of course, the COVID-19 pandemic shifted this reality a little bit. With many Americans in need of insurance, medical assistance and some sense of stability, Congress sought new ways to alleviate the impact.

The solution? A continuous enrollment provision included in the Families First Coronavirus Response Act. Basically, if states wanted to keep their federal funding, they needed to continually enroll beneficiaries throughout the COVID-19 pandemic. This meant states couldn’t disenroll beneficiaries even if their eligibility status changed, marking a huge shift in how insurance agents handled enrollment periods. 

Now, the continuous enrollment provision is ending. The Consolidated Appropriations Act of 2023 discontinues this provision while also scaling down federal Medicaid matching funds through the remainder of 2023. To ensure that everyone who is currently on Medicaid meets the requirements, every state is conducting a review of their beneficiaries. The process of reviewing eligibility of those on Medicaid is being referred to as the “unwinding.” 

So, just as the start of provision caused a major shift, its ending represents another set of changes and challenges!

What to expect during the unwinding of the continuous enrollment provision

The period from February 2020 to March 2023 saw huge growth in the number of Medicaid beneficiariesand corresponding decreases in the rate of uninsured Americans. In that period alone, 23.3 million new enrollees joined Medicaid, bringing the total number of beneficiaries up to 95 million individuals. 

The continuous enrollment provision kept current beneficiaries enrolled in Medicaid even if their eligibility status changed. Now, if they’re no longer eligible, those beneficiaries are set to be disenrolled from the program. 

Determining what percentage of the new enrollees were directly aided by the continuous enrollment provision, and how many will be affected now, is difficult. We do know, though, that a combination of economic distress from the pandemic and the expansion of Medicaid the potential number of people affected by this review will be enormous. 

Expect to hear from concerned clients during this unwinding period. Many will be worried about their eligibility status, even if they aren’t at risk. If you have clients who actually are at risk, be ready to explore new, affordable plan options with them quickly. 

Who is at the highest risk of losing coverage? 

The expectation is that the main group losing coverage will be those whose eligibility has changed. But predicting the true impact of the unwinding is more difficult in practice. Experts suggest that 5-14 million Americans will lose their Medicaid coverage in the course of this process, with some estimates going even higher.

In theory, the groups with the highest enrollment while the provision was in place may be at higher risk of losing their coverage now. Around 5% of new enrollees during the provisional period were seniors, equaling about 1.3 million individuals. (Another 31% of new enrollees were children under 19 and 38% were other adults eligible under the Affordable Care Act.)

While Medicare wasn’t directly impacted by the continuous enrollment provision, changes to Medicaid still impact seniors with Medi-Medi plans. So, if you work with Medi-Medi clients, you’ll want to ensure they’re aware their eligibility is being reviewed. 

New enrollees aren’t the only ones in danger of losing their coverage. Beneficiaries who historically experience barriers to re-enrollment are also at higher risk. This includes

  • those who moved (and thus changed their contact information), 
  • groups with limited English proficiency, and
  • individuals with disabilities. 

These individuals always face difficulties completing their enrollment paperwork. In conjunction with the unwinding, they’re at an even higher risk of disenrollment without a clear path forward. 

With this in mind, carefully review your client lists and identify whether they include new Medicaid enrollees or individuals with barriers to re-enrollment. Then target your outreach toward these individuals to ensure they don’t experience a gap in coverage. 

How will the Medicaid unwinding vary between states? 

The continuous enrollment provision was a federal incentive. The goal was to encourage adoption by states if they wanted to keep their federal funding in place. Since the execution of Medicaid programs is always handled by individual states, the unwinding of this provision will also be left to each state to oversee on its own.

There are already key differences in how each state is handling the unwinding period, both in terms of timing and in communicating with beneficiaries. Eight states began their renewals in February, with 15 following in March and 28 more in April. And while some states reported that the unwinding process would take less than 12 months, the majority say renewals will take 12-14 months to complete. 

In terms of communication, states vary in their commitment to contacting Medicaid beneficiaries before disenrolling them. All states have made efforts to update contact information for these individuals over the past year. Beyond this, three-quarters of states committed to following up with beneficiaries before terminating their coverage. 

Your clients view you as a local expert! So, you’ll need to be up to speed with the communication and timeline expectations for your state. The Medicaid renewal commitments for each state can be found here

How can I advocate for clients? 

This may be a scary time for some of your clients. As you know, eligibility requirements and timelines can feel like a big unknown to clients, creating stress in the face of uncertainty. The stakes are also high because your clients might be worried about losing access to needed medical care for themselves and their families. 

Beneficiaries should be expecting communication from their home stateespecially if they’re in danger of disenrollment. But they may have barriers to accessing this communication, or they may just miss it. A note from their insurance agent can go a long way toward putting a friendly, human face on this issue. Now more than ever, you’re in an excellent position to offer support and clarity to your clients. 

If you have clients on Medi-Medi plans, there’s a strong possibility you’ll have some with eligibility changes. Take this time to make sure you’re up to date on the affordable offerings in your state for those transitioning off Medicaid. 

Remember, you aren’t in this alone. The Medicaid unwind is national news and insurance agents across the country are working to effectively manage this transition alongside their clients. For questions on the unwinding, contact us today.


image credit: shutterstock/VIREN DESAI