The Covid-19 Public Health Emergency is officially ending on May 11th, and the federal government is winding down its various emergency funding streams tied to COVID, including emergency funding that went to increasing state Medicaid programs. As a result, states will begin reevaluating who is still eligible for Medicaid as budgets are cut. States can take up to 14 months to complete all renewals. Pennsylvania began this reevaluation at the beginning of March 2023. You may have received something in the mail saying your healthcare provider is renewing your coverage or is dropping you from it, and you need to find another provider. Starting April 1, 2023, states are allowed to disenroll folks from Medicaid that were covered under the extension of the program via funding for the health emergency. Pennsylvania does not plan on doing this until May. You can see when other states plan on doing this here.
Starting in May, Medicaid recipients who have not had their eligibility successfully renewed in the past 12 months may be disenrolled for procedural reasons, such as non-response to a renewal form, per Centers for Medicare & Medicaid Services (CMS) guidelines. Terminations for individuals the state has redetermined as ineligible for Medicaid and CHIP may occur on or after this date. Kaiser Health News estimates that between 5 million and 14 million individuals could lose their Medicaid coverage. The folks identified by Kaiser Health News as most likely to lose coverage and not get re-enrolled in care are “people who have moved since the start of the pandemic, those with limited English proficiency and people with disabilities.”
Those impacted by dis-enrollment may be able to seek care through the Affordable Care Act marketplace or through the CHIP program. In addition, folks who are denied for procedural reasons could reopen applications or apply in exchange. In some states where Medicaid has not been expanded, residents may not have access to support with Affordable Care Act Healthcare Premiums. You can find more information on the steps you need to take to renew your coverage here.
As the COVID-19 Public Health Emergency ends, so too does the temporary Medicaid coverage for vaccinations, testing, and treatment to uninsured folks. This means that anyone who is uninsured will have to pay for these resources out of pocket. The minimum wage in Pennsylvania remains at the federal minimum of $7.25, and so these added costs for Pennsylvanians living in poverty are sure to be a great barrier to access to health services.
As de-enrollment takes place, states are required to meet the following process conditions to ensure that impacted people are aware of the process.
- States must comply with federal CMS requirements or seek authorization for a different arrangement.
- States must have a robust plan to attempt to obtain up-to-date contact info for all beneficiaries.
- States must make a good faith effort to contact beneficiaries by more than 1 modality before kicking them off coverage.
If states do not comply with the listed conditions, they will face the following accountability measures via the Centers for Medicare & Medicaid Services (CMS)
- Financial penalties for states who don’t comply with reporting requirements, and redetermination requirements
- Federal government can pause redeterminations if a state isn’t complying
- Federal funding will continue but wind down between April and Dec 1st. One condition of getting funding through Dec 31st is that states cannot adopt more restrictive procedures.
TeleHealth
Increased funding for Medicaid access under the covid-19 emergency was not limited to enrollment. The emergency act also widely expanded telehealth access for recipients of Medicaid across the board. As has been experienced, this widely increased access to healthcare for a range of people, not limited to those with disabilities and transportation issues, but for working class folks with little to no time to take care of themselves.
Many people rely on telehealth appointments to receive their treatment and or medications. In order to protect COVID-19 Public Health Emergency flexibilities around broader prescribing of controlled substances via telehealth, the DEA has issued rules on virtual prescribing of controlled substances before the Public Health Emergency expires. You can see more information regarding those rules here.
A newly proposed rule would mandate an in-person doctor’s visit to get access to a controlled substance, such as Buprenorphine, rather than via telehealth. This could also affect people seeking mental health care, transgender care, treatment for opioid use disorder, and even remedies for severe coughs. The issue here is that most Telehealth patients reported that it takes at least a month, sometimes longer, to get an in-person appointment. So, this newly proposed mandate could lead to patients suffering from Substance Use Disorder (SUD), a Mental Health Disorder, or someone transitioning going days or even weeks without their treatment.
CCJ will be watching for updates and will be providing new information as we receive it. For more information on this or if you have a story about your renewal or denial experience you would like to share, please contact our Field program Coordinator, Paul, at 724-229-3550 or paul@centerforcoalfieldjustice.org.
