Public health Medicaid emergency allocation policies affecting the elderly and persons 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 Coronavirus Response Act (FFCRA) require states to provide continuous coverage for Medicaid enrollees by the end of the month in which the public health emergency (PHE) COVID-19 ends in order to receive increased federal funding. PHE is currently in effect through July 15, 2022, and is expected to be extended through 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 to avoid inappropriate loss of coverage as states review eligibility for large numbers of enrollees.

This issue summarizes expected changes to enrollment in age- or disability-based (“non-MAGI”) pathways following the end of PHE, state enrollment and renewal policies for non-MAGI groups beginning January 1, 2022, and state plans to 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 pregnant people, parents and children on low incomes. Data were collected from March to May 2022 in the KFF State Employee Medicaid Eligibility Survey. 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 report non-MAGI enrollment increased during PHE against COVID-19, and most states expect coverage losses at the end of PHE. Of the 37 states that responded, states most often cited a change in income followed by returned mail or an inability to contact records as the primary reason for expected coverage losses. On average, 10 percent of non-MAGI enrollees are expected to lose coverage at the end of PHE (14 states responded).
  • Understaffing and enrollee confusion were the most commonly identified issues expected to affect non-MAGI enrollees as states return to normal operations when PHE ends.
  • Most states (23 of 35 respondents) currently renew eligibility for a small share (<25%) of non-MAGI enrollees on an ex parte basis (without requiring 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 making 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 plan 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 switch to other coverage (such as Medicare or Marketplace coverage) after PHE ends.

Looking ahead to the end of PHE, ensuring that eligible people remain enrolled or successfully transition to other coverage can help minimize coverage gaps. 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 enrolled in Medicaid in pathways based on old age or disability have experienced lower dropout rates than children and non-elderly adults enrolled solely on the basis of low income because are less likely to experience changes in income or other factors affecting their current Medicaid eligibility. However, at the end of PHE, when millions of enrollees will need to complete renewals, staff shortages and enrollee confusion about how to navigate the process could increase the risks of losing coverage. State policies to streamline eligibility and enrollment, such as increasing the proportion of non-MAGI renewals completed ex parte, can minimize staff burden and promote continuity of coverage.

Leave a Comment

Your email address will not be published.