Surabhi Dangi-Garimella, Ph.D.

The COVID-19 national emergency and public health emergency (PHE) declared by the Trump Administration in early 2020 are now set to expire on May 11, 2023 instead of March 1 and April 11, respectively. The White House said in the announcement that the extension will prevent chaos and confusion in state budgets and in healthcare facilities that would need to retrain staff and establish new billing processes. However, the emergency use authorization for COVID-19 countermeasures, declared in April 2020, will remain in place and will not end in May 2023.

A Slump in Medicaid Enrollment Expected

States may see a big impact on Medicaid enrollment rates when the PHE ends. The Families First Coronavirus Response Act (FFCRA), enacted by Congress at the beginning of the pandemic, required states to keep people continuously enrolled in Medicaid in order to receive enhanced federal funds. Consequently, Medicaid enrollment saw a huge jump and the uninsured rate dropped—90.9 million people were enrolled in Medicaid/CHIP in September 2022, which was nearly 28% higher than the enrollment at the beginning of the pandemic in February 2020. Coverage preservation during the pandemic increased state spending on Medicaid but was well-compensated by the increased federal funding that states received.

However, the Consolidated Appropriations Act, 2023 decouples Medicaid continuous enrollment provisions from the PHE on March 31, 2023. So, come April 1, 2023, states can start rolling off Medicaid enrollees—the Department of Health and Human Services estimates as many as 15 million individuals will leave the program dues to loss of eligibility (and need to transition to another source of coverage) or lose coverage despite being eligible (due to administrative churning, which had stopped during the continuous enrollment period). 

CMS Requires States to Be Prepared for End of PHE

A CMS guidance in early 2022 urged states to chalk out a plan for coverage continuity and avoiding wrongful end of coverage at the end of the PHE. When surveyed in January 2022, 27 states had a plan in place for prioritizing outstanding eligibility and renewals for Medicaid enrollees when the continuous coverage enrollment period ends:

  • 11 states will take a population-based approach (target individuals who have a change in circumstances and/or are not likely to be eligible), 8 will take a time-based approach (fresh renewals based on the individual’s renewal month), and 8 are planning a hybrid approach (population and time-based)
  • 15 states will use electronic data matches to identify and target enrollees who will lose eligibility (due to higher income) at the end of the continuous enrollment period, 19 will not use this strategy, and 16 are yet to decide either way
  • 41 states plan to take 9-12 months for redeterminations, four states are targeting 6-9 months, and three states may take 3-6 months
  • In addition to sending a renewal form to enrollees, several states are planning to send reminders via mail, email, individual/automated phone calls, or text messages
  • Many states are planning to boost workforce capacity at the end of the PHE 

A wide range of healthcare flexibilities imbued by the PHE will soon end or metamorphose, including coverage for COVID-19 testing, treatment, and vaccines; technicalities of telehealth coverage such as receiving telehealth at home, via a smartphone, and from a provider in a different state. It’ll be interesting to track states responses to these changes and its impact on the wellbeing of communities.  


Surabhi Dangi-Garimella, Ph.D. is a biologist who provides education, communication, and strategic support to non-profit groups via her consultancy, SDG AdvoHealth, LLC.