During the coronavirus pandemic, Medicaid played a key role in providing coverage to millions of people who lost their jobs or their health coverage. In addition, provisions included in the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief and Economic Security (CARES) Act require states to maintain eligibility standards and ensure continued enrollment in Medicaid until the end of the Public Health Emergency (PHE) in order to be eligible for enhanced federal Medicaid funding. This report provides data on state Medicaid and CHIP eligibility levels and provides an overview of key aspects of state enrollment and renewal procedures in place during COVID-19 PHE based on information from the 19th Annual Survey of Medicaid and CHIP Managers in All 50 States. and DC. The report includes policies for children, pregnant women, parents and other non-elderly adults whose eligibility is based on the modified adjusted gross income (MAGI) financial rules. The main findings of the survey are as follows.

  • In 2021, eligibility for Medicaid and CHIP is largely unchanged from 2020 due to Maintenance of Eligibility Requirements (MOE). State eligibility levels in all groups remained stable throughout 2020 due to the increase in FFCRA’s FMAP and MOE provisions. Children and pregnant women continue to be covered at higher income levels while the coverage gap for low-income adults persists in the 14 states that have not implemented the widening. In October 2020, Nebraska became the 37e the state, including the District of Columbia, to implement the expansion of Medicaid after its passage through a voting initiative in 2018. Voters in Missouri and Oklahoma have endorsed similar initiatives in 2020 and will implement the expansion later in 2021.
  • Even with the MOE, most states renew coverage when possible and take other steps to prepare for the end of the PHE. Most states renew coverage when they are able to confirm continued eligibility through electronic data sources. Two-thirds of states that process renewals also report that they send renewal forms or information requests when they are unable to automatically renew coverage through other data sources. While states cannot terminate coverage for failure to respond or ineligibility, sending renewal requests allows states to extend coverage for those who respond with proof that they remain eligible. Additionally, just over a third of states have established a new 12-month renewal period when processing a change in circumstances that results in a new path of eligibility. As states prepare for the end of the PHE, more than a third are continuing or planning to take proactive steps to update mailing addresses for registrants. These actions will help reduce arrears and minimize interruptions of coverage at the end of the PHE. Only 17 states have reported an increase in new requests since the onset of COVID-19 PHE. This could be due to smaller than expected decline in employer-sponsored insurance, decrease applications at the onset of the pandemic due to office closures and the elimination of new claims (when someone loses coverage, often for procedural reasons, then reapplies soon after) due to MOE requirements .
  • The administrative actions and Congressional proposals will have implications for Medicaid coverage and enrollment as well as for the state’s efforts to plan for the resumption of normal operations after PHE. In one letter to governorsThe Biden administration noted that the PHE is likely to extend for the entirety of 2021 and promised 60 days notice before the PHE is terminated or allowed to expire. In December 2020, CMS released advice outlining how States should release emergency authorities and resume normal processing of eligibility and enrollments after the end of the PHE. While the expansion of the PHE gives States more time to prepare for its termination, it is possible that CMS will issue additional clarifying guidelines, which would affect State planning efforts. The administration also recently announced that it will revise the Medicaid waiver demonstration policy and rescind the work requirements guidelines and may also revise the capped funding demonstration policy. In addition, the last COVID Legislative Relief Package includes provisions to provide states with the option of expanding coverage for pregnant women up to 12 months after childbirth in Medicaid and CHIP and to provide financial incentives to states without expansion to adopt the expansion of Medicaid. The eligibility and enrollment policies presented here provide a baseline against which to assess changes states may make in response to these federal policy changes.


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