As many of you are aware, The Public Health Emergency (PHE) declared by the Department of Health and Human Services (DHHS) in early 2020 and the subsequent legislation, the Families First Coronavirus Response Act (FFCRA), passed by Congress had a positive outcome for millions of Medicaid enrolled members; allowing them to keep their coverage as long as the PHE was in effect regardless of current eligibility.
On December 29, 2022, the Consolidated Appropriations Act, 2023 was enacted which contained an important change to the continuous enrollment condition. This law removed the linkage of the ending of continuous enrollment to the PHE and instead has set a definite end to this provision as of March 31, 2023. Beginning April 1st, states may terminate Medicaid enrollment for individuals who are no longer eligible.
As of February 1, states may initiate their process for evaluating their Medicaid beneficiaries and redetermining their eligibility status for continued Medicaid benefits. CMS has given states flexibility in the way they complete this process; however, they have provided the following guidance:
Every member must be redetermined through the renewal process
States are allowed up to 14 months to return to normal
o Initiate renewals within 12 months, by March 31, 2024
o Complete renewals within 14 months, by May 31, 2024
Submit required documentation to CMS detailing the state’s renewal plan
Submit baseline data and report on specific metrics demonstrating progress
For further information on this please see the CMCS Information Bulletin dated January 5, 2023 found here.
It is important that Federally Qualified Health Centers (FQHCs) begin preparing now. While each state will have unique circumstances around their chosen approach to Medicaid redetermination, there are a few things that all FQHCs can begin doing.
There are numerous resources available to FQHCs with helpful tips and best practices for proactive steps to support this process and minimize the impact on our patients and our organizations. Summarized below are some general recommendations all FQHCs can implement.
1) Educate and assist patients in updating their contact information with their state Medicaid agency so they receive requests for information.
2) Educate ourselves on our state’s specific renewal process
3) Encourage patients to take action and respond to renewal notices in a timely manner
4) Educate patients that may no longer be eligible on other coverage options
Finally, flexibility and adaptation are key for FQHCs to navigate this change for patients and the health center, alike. Staying in tune with state agency resources and taking the initiative to communicate early and often with potentially affected patients is essential. Medicaid is typically an FQHC’s highest payor, and the patients represent our target population. Therefore, it is in both parties’ best interests to ensure that eligible patients receive uninterrupted coverage, and for those that may be above the income qualifications to help them with alternatives, so they can continue to receive primary care and focus on the well-being of themselves and their families.