By Carrie Dorn, MPA, LMSW – NASW Senior Practice Associate
At the start of the COVID-19 pandemic in January 2020, the Secretary of the U.S. Department of Health and Human Services first declared a 90-day public health emergency (PHE). The PHE declaration allowed flexibility in health care funding and regulations to respond to the pandemic. Since January 2020, the PHE has been renewed 11 times and is currently in effect through mid-January 2023.
When the COVID-19 PHE ends, which is expected in 2023, state agencies will begin the “unwinding” of continuous Medicaid and Children’s Health Insurance Program (CHIP) by going through the redetermination process for all enrollees. Up to 15 million people may be at risk of losing health insurance coverage.
End of the Public Health Emergency (PHE)
The exact end date of the PHE is not known at this time. The PHE was renewed in October 2022 and remains in effect until at least January 11, 2023. The Biden-Harris administration has committed to providing a 60-day notice to states before the PHE will expire. No notice was given in November 2022, so it is assumed that the PHE will continue beyond mid-January 2023. If the PHE is renewed again in January 2023, it will continue until mid-April 2023.
During the PHE, Medicaid and CHIP enrollees will continue to maintain coverage and cannot be disenrolled.This is a critical time for social workers to help individuals and families anticipate the redetermination process that will happen in the months ahead. This blog is intended to provide an overview of unwinding and strategies to reduce coverage losses.
What is Unwinding?
Unwinding refers to the return to normal operations for Medicaid and CHIP agencies after the COVID-19 PHE ends. In 2020, Congress passed the Families First Coronavirus Response Act that provided states enhanced funding for Medicaid and CHIP and required states to adopt continuous coverage for individuals and families through the end of the PHE. Individuals were not disenrolled from Medicaid, even if their income and eligibility status changed. As a result, over the past three years Medicaid and CHIP programs have grown significantly to 90 million enrollees in July 2022 as compared to 71.2 million in December 2019, according to the Kaiser Family Foundation.
When the PHE ends, states will begin conducting redeterminations again and will disenroll those who are no longer eligible. Individuals and families with income above the Medicaid threshold may be eligible to gain coverage on the Health Insurance Marketplace.
A concern of advocates, including NASW, is that individuals and families will lose coverage because of lack of communication with recipients to verify income. State agencies will be in contact with enrollees to confirm continued eligibility.
However, state agencies may have outdated contact information such as mailing and email addresses and phone numbers for recipients. These communication barriers may lead to loss of health care coverage for families that continue to meet eligibility requirements.
The Centers for Medicare and Medicaid Services (CMS) and advocacy organizations are providing guidance on ways to prepare individuals with Medicaid for the upcoming redetermination process. Each state has written an “unwinding operational plan” with its strategy for conducting redeterminations. The Georgetown University Center for Children and Families has developed a 50-State Unwinding Tracker for information on each state plan.
NASW urges states to make unwinding plans public so that advocates can identify gaps, and CMS is encouraging states to seek input from stakeholders.
NASW and advocates strongly encourage states agencies to use multiple means of outreach to contact households for information, including mail, text, and email. NASW supports the expanded use of “ex parte” renewals (also known as automated renewals) when state agencies use available electronic data sources to verify eligibility (such as SNAP information). This practice can support continuity of health insurance coverage and streamline the redetermination process. State agencies are also partnering with other health insurance plans, health providers, and local organizations to conduct outreach to individuals who may be at risk of losing coverage.
Social Work Advocacy
Social workers are important stakeholders who help individuals maintain their Medicaid and CHIP coverage– or facilitate a smooth transition to another health insurance program. Social workers, and the organizations in which they work, help individuals and families who receive Medicaid and CHIP to contact state agencies proactively to verify or update their contact information. Social workers also encourage clients to be on the lookout for mail, emails and phone calls that may alert them to the need to provide information. Many states are already conducting campaigns to ask recipients to be in contact with Medicaid and CHIP agencies to update their information. Organizations can amplify these campaign messages in their offices and on social media platforms.
If individuals no longer qualify for Medicaid or CHIP because their income has increased, they may be able to get health coverage through an employer or the healthcare marketplace. Social workers help individuals navigate through this transition.
Social workers can be vocal in responding to state unwinding plans and highlighting areas for improvement. They recommend strategies for effective outreach and communication with hard-to-reach populations. Medicaid and CHIP agencies benefit from the insights and experience that social workers have in engaging underserved individuals and families.
NASW will continue to monitor resources that are helpful for advocacy at the state level and provide additional guidance on how social workers can support individuals and communities as the PHE ends.
Update, January 18, 2023:
With the passage of the Consolidated Appropriations Act, 2023 (also known as the omnibus appropriations bill), Medicaid unwinding is no longer determined by the end of the COVID-19 Public Health Emergency (PHE). The Consolidated Appropriations Act, 2023, passed in December 2022, keeps the Medicaid continuous enrollment provision in effect through March 31, 2023, and Medicaid disenrollments can begin on April 1, 2023. States have up to one year to initiate renewals. Detailed information can be found in the CMCS Bulletin from January 5, 2023, Key Dates Related to the Medicaid Continuous Enrollment Condition Provisions in the Consolidated Appropriations Act, 2023. On January 11, 2023, the COVID-19 Public Health Emergency was renewed and will be in effect until mid-April 2023.
- Medicaid Unwinding and Returning to Regular Operations after COVID-19
- Medicaid and CHIP Continuous Enrollment Unwinding – Toolkit- English
- Medicaid and CHIP Continuous Enrollment Unwinding – Toolkit- Spanish
- Kaiser Family Foundation – 10 Things to Know About the Unwinding of the Medicaid Continuous Enrollment Requirement
- Families USA – Not a Moment to Lose: Critical Changes States Should Implement to Prevent Medicaid Coverage Losses
- Office of the Assistant Secretary for Planning and Evaluation Issue Brief Unwinding the Medicaid Continuous Enrollment Provision: Projected Enrollment Effects and Policy Approaches
- Georgetown University Center for Children and Families 50-State Unwinding Tracker
- Urban Institute Fact Sheet – Most Adults in Medicaid-Enrolled Families Are Unaware of Medicaid Renewals Resuming in the Future
- CMS- Ex Parte Renewal: Strategies to Maximize Automation, Increase Renewal Rates, and Support Unwinding Efforts
Examples of State Outreach Material
- Arkansas – Update Arkansas Graphics
- Arizona – AHCCCS Preparing for the End of COVID-19: Return to Normal Renewals
- California – Medi-Cal Ambassador Resources
- Kansas – KanCare Promotional Videos in Spanish by El Centro, Inc.
- Montana – Cover Montana Medicaid & HMK Continuous Coverage Unwinding: Communications Toolkit
- Virginia – FAMIS Promotional Material
- Washington – Apple Health End of the PHE Communications Toolkit