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The state of the health insurance industry may be steering back to some degree of normalcy, but not without ongoing shifts and changes. It has certainly been a roller coaster over the last several months, and State Health Officials (SHO) continue to navigate the unpredictable aftermath of the pandemic and the Public Health Emergency (PHE), including the upcoming Medicaid reassessment.

Soon to be issued regulations from the Centers for Medicare and Medicaid Services (CMS) will help states visualize a roadmap back to normal, including with the latest requirements for Medicaid reassessments. You might be wondering what your state can expect with your statewide efforts to review eligibility metrics for programs like Medicaid and CHIP. And while the future trajectory may still be clouded, here is what we know about what you can expect moving forward and toward the end of the PHE.

Predictions Are Essentially Only Guesses

Let us preface this conversation by pointing out that predictions, despite the analytics, are only guesses. And if the pandemic taught the healthcare and health insurance industries anything, it is that no amount of data collection will necessarily provide a clear outlook of what to expect. For example, analysts predicted the economic shutdowns would drive unemployment levels that rivaled those of the Great Depression. But the unemployment rates are rebounding much faster than originally projected. Every state experienced a different pandemic impact, adding to the variances in the return-to-normal predictions. As you develop your Medicaid reassessment plans, just know that your expectations now might vary from actual outcomes.

Enrollment Rates Are Rising

Everyone anticipated a surge in Medicaid enrollment because of the pandemic. But that rate of growth has been a little harder to pinpoint. On average, enrollment rates across the board are up about 15 percent. As the PHE winds to an end and with the increase of vaccine distributions nationwide, state budget officials are looking to find out if those enrollment rates will continue to rise. State Health & Value Strategies conducted analysis tracking Medicaid enrollment rates across 21 states, confirming median total enrollment rates from February 2020 to January 2021 idled around 14.5 percent; this level of increase is huge when state officials were experiencing Medicaid enrollment declines between 2017 and 2019. The state residents making up these increased enrollment numbers primarily represented those who were affected by job losses, the non-elderly, and non-disabled adults.

Some States Saw Above-Average Enrollment Rate Increases

When you look at the percentages of Medicaid enrollment, it may not seem like an imposing average. But in actual numbers, that is an additional 9.3 million Americans jumping into the system; those trajectories vary. Job losses, for example, did not all occur overnight. Many employers temporarily furloughed staff at first, only to finalize layoffs later in the year. This created a steady stream of newly Medicaid and CHIP eligible candidates over a period of months. Other considerations impacted the rate of enrollment, too, like the federal provisions within the Families First Coronavirus Response Act (FFCRA) that mandated states to offer continuous coverage.

While the average enrollment rates increased by nearly 15 percent, other states saw much higher rates of adoption. Utah, for example, recorded jumps in Medicaid and CHIP enrollment from February 2020 to January 2021 of 25 percent. Other states with more than 20 percent surges in enrollment include Hawaii, Oklahoma, Kentucky, Nebraska, and Nevada. At the lower end of the increase spectrum, states like Alaska, South Carolina, Alabama, and Tennessee saw adoption hikes of less than ten percent. But regardless of which state you call home; it is important to know that every state in the country reported enrollment increases.

What the End of the PHE May Mean for Enrollment Rates

Sure, the Medicaid enrollment rates recorded increases during 2020, during the critical points of the pandemic. But what about this year and the next two years of enrollment benchmarks? With the PHE ending soon, should states be prepared to lose enrollment with the upcoming round of reassessment? Many of the industry analysts are predicting, yes, but with an asterisk. CMS is intent on supporting states in transitioning back to normal enrollment eligibility operations. However, there will be a continued focus on minimizing any burdens to Medicaid and CHIP beneficiaries. Each state will emerge from the pandemic impacts differently, based on active, positive cases of COVID-19, strained healthcare systems, economic impacts, general populations, and budgets. States should be implementing Medicaid reassessment efforts now and planning for future reassessments.

The Current PHE Is Coming to an End

In a letter to the state governors, the Biden administration says the PHE will remain in place throughout the duration of 2021. Any official, hardline terminations will come with a 60 days’ notice, allowing enough time for states to plan and adjust. It may be helpful to know that you will have some leeway in the timeline to return to pre-PHE rules.

The conditions regarding the 6.2 percent Federal Medical Assistance Percentage (FMAP) point increase, including eligibility standards and procedures, will technically expire on the first day of the month that follows the official calendar quarter of the PHE ending. Premium restriction changes will revert on the first day of the month, following the calendar quarter of the PHE ending. The same timelines apply to the ending of coverages for COVID-19 testing and treatment and cost-sharing exemptions. Continuous enrollment, part of Section 6008(b)(3) of the FFCRA, will expire the first day of the month after the official end of the PHE.

CMS is requesting states to reassess the eligibility of their Medicaid populations. If you are interested in partnering with resources that help process transactions, contact Softheon. We currently provide daily Asset Verification Services to several states and with the capability of processing more than 50 transactions per second. Softheon also supports Medicaid reassessment efforts. While you may not have the crystal ball to help you predict what the exact future of Medicaid will look like in your state, you can count on Softheon to be a trusted partner for every step of the transition back to pre-PHE conditions.

Meet the Author

Medicaid Reassessment

Josh Schultz is a Senior Policy Analyst at Softheon, where he advises the company on health policy issues affecting businesses and government health agencies. Prior to Softheon, Josh worked for a non-profit agency assisting Medicare beneficiaries, a technology company, and consulting firms.