What You Should Know About Unwinding Continuous Enrollment for Medicaid and CHIP

In the first year of the COVID-19 pandemic, the federal government provided an extra 6.2 percentage points in their Medicaid funding to states in exchange for allowing continuous enrollment – that is, pausing annual review of eligibility – for most Medicaid beneficiaries for as long as the official Public Health Emergency (PHE) declaration remained in place.  Since that change, enrollment in Medicaid and the Children’s Health Insurance Program (CHIP) has grown by almost 30 percent and, as of September 2022, nearly 91 million individuals were enrolled across the programs.

After several extensions, the PHE is set to expire in mid-April; however, new legislation calls for continuous enrollment and other pandemic-related flexibilities to end on March 31, 2023. Beginning on April 1, states claiming the temporary increase will be able to end Medicaid or CHIP enrollment for individuals, following a review of their eligibility. As explained in a letter to State Health Officials, states may begin disenrollment as early as February 1, 2023.  Once the process begins in each state, they will have 12 months to “unwind” expanded eligibility and return to their normal enrollment process.

Eligibility and renewal systems, staffing capacity, and investment in end-of-PHE preparedness vary across states. Because of the volume of new beneficiaries, federal health officials anticipate loss of coverage for millions of individuals and families.

To smooth the transition, the Centers for Medicare & Medicaid Services (CMS) is working with states to help them:

  1. Prepare for the renewal process and educate Medicaid/CHIP enrollees about the upcoming changes, and
  2. Ensure beneficiaries take the necessary steps to renew coverage, or transition to other coverage if they’re no longer eligible.

In its Communications Toolkit for Continuous Enrollment Unwinding, CMS identifies health care providers and clinics, local health departments, community-based organizations, and even schools and places of worship as effective avenues for outreach.

The Federal Office of Rural Health Policy will continue to monitor what’s happening, translate the unwinding process and its effects for rural stakeholders, and keep you up to date on significant news and deadlines.

Helpful Links

U.S. Department of Health & Human Services – Projected Enrollment Effects and Policy Approaches

Centers for Medicare & Medicaid Services guidance, official documents, and communications toolkits in seven languages and Engaging Managed Care Plans to Maximize Continuity of Coverage

Federal Communications Commission – Action to Ensure Americans Receive Critical Information on Health Care Coverage

Georgetown Health Policy Institute50 State Unwinding Tracker

Kaiser Family Foundation – 10 Things to Know about the Unwinding of the Medicaid Continuous Enrollment Provision