Effective April 16, 2022, the U.S. Health And Human Services (HHS) Secretary Becerra renewed the COVID-19 Public Health Emergency that has been in effect since January 31, 2020. The current extension will expire on July 15, 2022, unless it is terminated before that date or extended further.
This means the maintenance of eligibility provisions in the Families First Coronavirus Response Act remain in effect until at least July 30, 2022 (the end of the month in which the PHE ends). As such, states, like Pennsylvania, must maintain their Medicaid eligibility requirements and enrollment procedures that were in effect as of January 1, 2020. Furthermore, if someone was enrolled in Medicaid on or after March 18, 2020, they cannot be terminated from Medicaid during the PHE except in very limited circumstances enumerated by state regulators. In exchange for not dropping people from Medicaid, the federal government is giving states a 6.2% increase in the federal matching rate for payments.
As stated above, this latest extension will expire on July 15, 2022, unless the PHE is extended further. A PHE can be extended as many times as deemed necessary by the HHS Secretary. Alternatively, the HHS Secretary could choose to terminate the PHE prior to July 15, but he would need to provide notice soon. The Biden Administration has promised to give states at least 60 days’ notice prior to the end of the PHE, so if the HHS Secretary has not announced an end to the PHE by May 16, 2022, we can expect he will issue a new extension by July 15.
Again, assuming DHS does not extend the PHE or terminate the PHE earlier, the current continuous coverage requirement would end July 30, 2022 (the end of the month in which the PHE ends). Once that happens, Pennsylvania will return to pre-PHE eligibility and enrollment rules, and will need to redetermine eligibility for impacted enrollees. This means Pennsylvania could begin redetermining eligibility for hundreds of thousands of Medicaid enrollees as early as August 1. This includes some 500,000 enrollees who under normal circumstances would have been terminated (perhaps due to changes in eligibility) and another 400,000 who have been maintained on Medicaid despite not returning renewal paperwork.
During public meetings held in April 2022, Pennsylvania Medicaid officials signaled that they plan to spread these eligibility redeterminations over a period of 6 months, rather than completing them all at once. During this 6-month period, enrollees who have been kept on Medicaid due to the PHE will receive renewal packets, which they will have 30 days to return with supporting documentation. Individuals who are still eligible will be renewed, while those who are found ineligible will receive a termination notice advising them of their appeal rights. Enrollees who fail to return their renewal notices will also receive a termination notice, but County Assistance offices will be allowed to reopen and review their application if they submit the missing documentation within 90 days. The Department is meeting regularly with stakeholders to develop a successful communication plan for affected enrollees and caseworkers. Managed care organizations in HealthChoices and Community HealthChoices are viewed as allies in communicating with enrollees and helping them with redetermination paperwork when the time comes.
SPECIAL NOTE FOR MEDICAID ENROLLEES: It is important to update your address and other case information with the County Assistance Office, especially if you have moved during the pandemic. All renewal documents will be mailed to the address on file with the County Assistance Office. To report changes to your case file, you can either a) submit the change online through your My COMPASS Account, or b) call the Statewide Customer Service Center toll free number at 1-877-395-8930 (in Philadelphia, call 215-560-7226.) DHS is also inviting Medicaid enrollees to sign up for text alerts to ensure they are getting timely updates on their benefits.
PHLP will continue to keep consumers informed of any updates around the PHE as we learn them.