Unwinding the COVID-19 Public Health Emergency

During the COVID-19 Public Health Emergency (PHE), originally declared in January 2020, federal legislation and Centers for Medicare & Medicaid Services policies have allowed state Medicaid agencies to respond to the needs of enrollees during the pandemic. These opportunities have included emergency flexibilities that states could implement using 1135 and 1915 Appendix K waivers during the PHE (more information available here).

Under the Families First Coronavirus Response Act, state Medicaid programs are eligible to receive an additional 6.2 federal funding match provided they meet specific Maintenance of Effort requirements, including providing continuous eligibility to those enrolled as of March 18, 2020 or at any time thereafter during the PHE. When the PHE ends, states will need to redetermine the eligibility of over 80 million Medicaid enrollees, including an estimated 37.3 million children.

The resources on this page provide further information about unwinding the COVID-19 PHE and its implications for state Medicaid programs, particularly as related to eligibility redeterminations. These resources provide information about what is expected of state Medicaid agencies, strategies for preventing the unnecessary loss of coverage, and how states can help transition children and families to other coverage (e.g., CHIP, Marketplace) if they are no longer eligible for Medicaid. If you have any questions, feel free to contact us at [email protected], we are here to help.

For up to date information about the status of the COVID-19 Public Health Emergency, visit the U.S. Department of Health and Human Services Public Health Emergency Declarations site: https://www.phe.gov/emergency/news/healthactions/phe/Pages/default.aspx

The Catalyst Center resource, Unwinding the Maintenance of Effort Requirement at the End of the Public Health Emergency (PHE): The Role of Title V Programs, provides an overview of Medicaid maintenance of effort requirements during the COVID-19 Public Health Emergency and implications for CYSHCN. Check it out here: https://ciswh.org/resources/phe-moe

The archived Catalyst Center COVID-19 Resource library is available here: https://ciswh.org/resources/covid-19-cyshcn-library-archive/

CMS Guidance and Resources

Medicaid.gov. Unwinding and Returning to Regular Operations after COVID-19.

    • Includes Guidance from CMS, State Reporting information, Tools and Templates, Communication Tools, and Other Resources.

Centers for Medicare & Medicaid Services (CMS). May 2022. Eligibility & Enrollment Processing for Medicaid, CHIP, and BHP During COVID-19 Public Health Emergency Unwinding Key Requirements for Compliance.

Centers for Medicare & Medicaid Services (CMS). March 2022. State Health Official Letter # 22-001. RE: Promoting Continuity of Coverage and Distributing Eligibility and Enrollment Workload on Medicaid, CHIP, and Basic Health Program Upon Conclusion of the COVID-19 Public Health Emergency.

    • Contains guidance for states related to timeline and procedures for Medicaid eligibility redeterminations at the end of the COVID-19 Public Health Emergency.

Centers for Medicare & Medicaid Services (CMS). March 2022. Medicaid and CHIP Continuous Enrollment Unwinding: A Communications Toolkit. 

Centers for Medicare & Medicaid Services (CMS). March 2022. Medicaid and Children’s Health Insurance Program Eligibility and Enrollment Data Specifications for Reporting During Unwinding.

Other Resources

Center on Budget and Policy Priorities. May 2022. Time to Get it Right: State Actions Now Can Preserve Medicaid Coverage When Public Health Emergency Ends.

Center on Budget and Policy Priorities. March 2022. Unwinding the Medicaid Continuous Coverage Requirement. Frequently Asked Questions.

Georgetown Center for Children and Families. August 2021. Webinar Series: Unwinding the COVID-19 Medicaid Continuous Eligibility Provision.

    • Part 1: August 2021. State efforts in preparing for the end of the PHE.
    • Part 2: N.D. State health advocates talk about providing input to state preparations.
    • Part 3: October 2021. How CMS is working with states to prepare, and more details about preparation, including communication strategies.
    • Part 4: November 2021. How the Build Back Better proposed legislation might impact Medicaid coverage.
    • Part 5: February 2022. Engaging Medicaid Managed Care plan around the end of the PHE.
    • Part 6: March 2022. Updated guidance from CMS.

Georgetown Center for Children and Families. August 2021. Unwinding the COVID Continuous Eligibility Requirement at the End of the Public Health Emergency: Tips for Advocates

National Academy for State Health Policy. December 2021. States Plan for the End of the Medicaid Continuous Coverage Requirement.

Kaiser Family Foundation and Georgetown Center for Children and Families. March 2022. Medicaid and CHIP Eligibility and Enrollment Policies are of January 2022: Findings from a 50-State Survey

Kaiser Family Foundation. March 2022. Unwinding of the PHE: Maintaining Medicaid for People with Limited English Proficiency.