The Centers for Medicare and Medicaid Services (CMS) has issued guidance for state Medicaid Programs setting out how an ‘unwinding period’ for PHE continuous coverage provisions could proceed: https://www.medicaid.gov/federal-policy-guidance/downloads/sho22001.pdf.
The guidance establishes a 12-month period during which Medicaid programs could complete re-determinations of enrollees afforded continuous coverage during the PHE: https://www.axios.com/coronavirus-pandemic-health-insurance-medicaid-e200bba0-7897-4b1e-8849-fb923367965d.html.
The guidance will permit states to conduct a more aggressive re-determination effort. States could, potentially, begin re-determinations as soon as 60-days prior to any announced PHE termination, with loss of enrollee coverage, based upon review, to commence as early as 60-days after the end of the PHE.