Public Health Emergency’s End Would Kickstart Medicaid Eligibility Re-Checks. Here’s How to Prepare
By Emma Freer

*Update: The PHE has been extended to Oct. 13.

After strong advocacy by the American Medical Association and other organizations, the U.S. Department of Health and Human Services (HHS) appears poised to extend the COVID-19 public health emergency (PHE) for a 10th time.*

This would be good news for the millions of Texans – predominantly postpartum women and children – who have benefited from continuous Medicaid coverage as a result of the federal disaster declaration. Nevertheless, these patients remain at risk of losing their coverage when the PHE does end, and Texas Medical Association and state public health officials are urging physicians and patients to prepare now for the implications of this looming coverage cliff.

TMA also is advocating for changes to the eligibility redetermination process patients will undergo to help ensure a smooth transition for patients, practices, and the safety net. 

HHS has said it will give states 60 days’ notice of the end of the PHE, which is currently slated for July 16. The department’s self-imposed notification deadline of May 16 passed without any such announcement after organized medicine, among others, pressed for a continuance. *(The PHE was extended in July to Oct. 13.)

“We urge the [Biden] Administration to maintain the PHE until we experience an extended period of greater stability and, guided by science and data, can safely unwind the resulting flexibilities,” AMA, the American Academy of Pediatrics, and 10 other national organizations wrote in a May 10 letter to HHS.

The federal Families First Coronavirus Response Act increased federal Medicaid matching dollars by 6.2% for states that agreed to maintain Medicaid coverage for anyone enrolled in the program from March 20, 2020, through the end of the PHE, including Texas.

The Texas Health and Human Services Commission (HHSC) estimates about 3 million Texans have had their Medicaid coverage extended as a result of the PHE.

The Centers for Medicare & Medicaid Services (CMS) has issued guidance around this unwinding, giving states 12 months after the PHE ends to initiate the eligibility process, plus an additional two months to complete any pending redeterminations.

In accordance with this guidance, HHSC has developed a three-phase plan to unwind continuous coverage and redetermine eligibility for an estimated 3.7 million Medicaid patients within eight months.

TMA and nine other Texas organizations dedicated to improving health care access are worried about this timeline and its potential impact on maintaining coverage for eligible individuals, reducing churn of patients, and preventing strain on the eligibility system.

“According to a recent survey of state Medicaid programs, Texas will be one of only [eight] states attempting to unwind the PHE-related continuous eligibility provision without allowing up to a year,” the signatories wrote in a March 31 letter to HHSC. “Additionally, unwinding too quickly will result in human and financial costs not only to millions of Texans, but also the state’s safety net, already strained by the pandemic.”

TMA and the other organizations offered a series of recommendations to prevent such an outcome, including urging HHSC to:

• Leverage data, automation, and flexibility to ease some of the burden on the eligibility system and workforce;
• Improve access to its “211” help program by increasing staff to address wait times, or by establishing a dedicated line for Medicaid patients to update their contact information; and
• Maximize patient outreach via text to ensure eligible Texans maintain coverage.

Regardless of how the unwinding process unfolds, many of those deemed ineligible will not have another coverage option, says Helen Kent Davis, TMA’s vice president of governmental affairs. This is largely because Texas has not extended health care coverage to low-income working adults and parents as allowed by the Affordable Care Act.

Additionally, Texas is one of six states where children enrolled in Medicaid and in the Children’s Health Insurance Program (CHIP) are especially at risk of losing their coverage when the PHE ends, according to a February report by the Georgetown University Center for Children and Families.

As a result, Texas physicians caring for Medicaid and CHIP patients face a potential increase in uncompensated care when the PHE does end.

Ms. Davis encourages practices to prepare by:

• Urging their Medicaid patients to complete their eligibility redetermination as soon as possible;
• Scheduling services for patients who might lose coverage, familiarizing themselves with potential coverage options for such patients; and
• Evaluating the financial impact of a potential increase in uncompensated care.

Practices also should expect to reverify patients’ Medicaid eligibility when the PHE expires, which can be done through:

• The Texas Medicaid & Healthcare Partnership (TMHP) Electronic Data Interchange;
• TMHP’s TexMed Connect;
• The Medicaid Client Portal; or
• TMHP’s Automated Inquiry System at (800) 925-9126.

In addition, HHSC encourages physicians to remind families to update their contact information with Medicaid to facilitate renewal when the PHE ends.