Medicaid Public Health Emergency Unwinding Policies Affecting Seniors & People 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 until the end of the month in which the COVID-19 public health emergency (PHE) ends in order to receive enhanced federal funding. The PHE is currently in place through October 2022, and is expected to be extended until at least January 2023. Centers for Medicare and Medicaid Services guidance recognizes that returning to normal operations when the PHE does end will require planning to avoid inappropriate coverage loss as states review eligibility for a large volume of enrollees.

This issue brief describes anticipated enrollment changes in pathways based on old age or disability (“non-MAGI”) after the PHE ends, state enrollment and renewal policies for non-MAGI groups as of July 1, 2022, and state plans for resuming normal operations when the 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 with low incomes. The data were collected from March through May 2022 in KFF’s survey of Medicaid state eligibility officials. Overall, 50 states and the District of Columbia responded to the survey, though response rates for specific questions varied. Key findings include the following:

• Most states reported that non-MAGI enrollment increased during the COVID-19 PHE, and most states anticipate coverage losses at the end of the PHE. Of the 37 states responding, states most frequently cited change in income, followed by returned mail or inability to contact the enrollee as the primary reasons for anticipated coverage losses. A median of 10 percent of non-MAGI enrollees are expected to lose coverage at the end of the PHE (14 states responding).
• Staffing shortages and enrollee confusion were the most frequently identified issues expected to affect non-MAGI enrollees as states return to normal operations when the PHE ends.
• More than half of states currently renew eligibility for some non-MAGI enrollees on an ex parte basis (without requiring information from the enrollee). However, 28 states have adopted at least one strategy to increase the share of ex parte renewals including relying on SNAP data without conducting a separate Medicaid determination (12 states), automating data checks (12 states), and expanding the number and type of electronic data sources used (11 states).
• Most states are planning 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 transition to other coverage (such as Medicare or Marketplace coverage) after the PHE ends.

Looking ahead to the PHE end, ensuring that eligible people remain enrolled or successfully transition to other coverage can help minimize gaps in coverage. This is especially important for seniors and people with disabilities, many of whom have chronic health needs and rely on long-term services and supports to meet daily needs. Historically, people who are enrolled in Medicaid in pathways based on old age or disability experience lower rates of churn, compared to children and non-elderly adults enrolled based solely on low income because they are less likely to experience changes in income or other factors affecting their on-going Medicaid eligibility. However, at the end of the PHE when millions of enrollees will need to complete a renewal, staffing shortages and enrollee confusion about how to navigate the process could increase risks of coverage loss. State policies to streamline eligibility and enrollment, such as increasing the share of non-MAGI renewals completed ex parte can minimize staff burden and promote continuity of coverage.