Unwinding the Continuous Medicaid Enrollment Provision

The Biden Administration recently announced an end to the COVID-19 public health emergency on May 11, 2023. When this happens, the emergency declaration that allowed millions of Americans continuous access to Medicaid – the state and federal program that provides health coverage to low-income people – also will end.

During the pandemic, the nation’s uninsured rate declined to a historic low of 8% in the first quarter of 2022, largely due to expanded access to Medicaid enrollment and Affordable Care Act (ACA) marketplace subsidies under the American Rescue Plan. Many people became eligible for Medicaid due to changes in income, employment or family composition.

As states prepare to unwind the continuous Medicaid enrollment provision, some 9.5 of enrollees will need to transition to another source of coverage such as the Affordable Care Act marketplaces or employer-sponsored insurance.

A recent analysis by the Kaiser Family Foundation (KFF) estimates that up to 14 million people enrolled in the Medicaid and Children’s Health Insurance Program (CHIP) could lose coverage when this provision expires. In addition, based on past patterns, the data suggests that most people who lose coverage will become uninsured for all or part of the following 12 months, with 41% eventually re-enrolling before the passage of an entire year (i.e., a phenomenon of cycling in and out of Medicaid coverage known as “churn.”).

KFF lists the following information as some of the top things to know about the unwinding of the Medicaid continuous enrollment provision:

• States are required to develop plans for how they will resume routine operations.
• Maximizing streamlined renewal processes can promote continuity of coverage.
• States can obtain temporary waivers to pursue strategies to support their unwinding plans.
• People who have moved, with limited English proficiency and with disabilities may be at greater risk for losing coverage.
• States can partner with health plans and community organizations to conduct outreach.
• Timely data on disenrollment and other metrics can help monitor how the unwinding is proceeding.

Overall, the number of people without health insurance could increase if people who lose Medicaid coverage are unable to transition to another source of coverage. A major takeaway is that states’ policies will have a major impact on reducing coverage disruptions and churn.

On January 23, 2023, The Centers for Medicare & Medicaid Services released updated guidance on how to reduce coverage disruptions for Medicaid enrollees and new federal reporting requirements to monitor states’ unwinding processes.


Pacific Federal is a Zenith American company and subsidiary of Harbour Benefit Holdings, Inc.