Earlier this month, U.S. Health and Human Services (HHS) Secretary Becerra renewed the COVID-related public health emergency (PHE). The latest extension will expire on April 16, 2022. This means the maintenance of effort provisions in the Families First Coronavirus Response Act remain in effect until April 30, 2022 (the end of the month in which the PHE ends). As such, states, like Pennsylvania, must maintain their Medicaid eligibility levels and enrollment procedures that were in effect as of January 1, 2020. If someone was on Medicaid as of January 1, 2020, they should not lose Medicaid coverage during the PHE. 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.
This extension was universally welcomed by Medicaid stakeholders in Pennsylvania. It means enrollment in Pennsylvania’s Medical Assistance program will not change significantly. Enrollment in Pennsylvania’s Medical Assistance Medicaid grew to 3,430,872 in December 2021, an increase of million (21%) from February 2020. Most of these enrollees are in managed care: 2.75 million are in a physical HealthChoices plan and nearly 400,000 are in a Community HealthChoices plan.
Should the PHE end in 2022, Pennsylvania will return to pre-PHE eligibility and enrollment rules, and will need to redetermine eligibility for impacted enrollees. Tens of thousands of Pennsylvanians could lose coverage if they are no longer eligible or face administrative barriers during the process despite remaining eligible.
During public meetings held in January 2022, Pennsylvania Medicaid officials reported it is not their intent to redetermine eligibility for all 3.4 million Medicaid enrollees the day after the PHE ends. The Department is meeting regularly to determine how to unwind the continuous enrollment requirement. 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.
A PHE can be extended as many times as deemed necessary by the HHS Secretary. Again, as stated above, the current continuous enrollment requirement ends April 30, 2022. This means states could begin processing renewals as of May 1, 2022. Given that the Biden administration has promised to give a 60-day notice to states prior to the end of the PHE, if it has not done so by February 15, 2022, one might expect that it would be extended again by April 16, 2022.
It is possible that the PHE is terminated prior to April 16, 2022. Tricia Brooks, at the Georgetown Center for Children and Families writes, “While many think this scenario is highly unlikely, it is possible. However, the administration would need to provide notice soon. So, for example, if the PHE was terminated on March 31, 2022, the Biden administration would need to inform states by January 31, 2022. Once we pass that date, we can be certain that the PHE will not end before April 16, 2022 (assuming the administration keeps its promise [to give states a 60 notice prior to the end of the PHE]).”