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ACA and Medicaid Membership Cliffs Loom for Fall and Year-End

There’s likely to be movement among Medicaid and Affordable Care Act (ACA) membership as the nation seems to be inching toward the end of the pandemic, at least from a regulatory standpoint.

Medicaid rolls swelled during the pandemic as relief packages guaranteed coverage for members even if they became ineligible over the course of the Public Health Emergency (PHE). But nothing lasts forever and states are bracing for an end date to the PHE, now expected to occur in mid-October. Political pressure is building to end the PHE, even as various entities plead for more time. If the PHE is not extended for another 90 days this fall, state Medicaid programs will need to begin re-verifying eligibility for members. There won’t likely be immediate disenrollment, but the process will begin and the clock will start ticking. To make things more challenging, the accuracy and success of this is likely to vary greatly according to state budgets and administrative effectiveness. There will be no coordinated, uniform approach. The U.S. Department of Health & Human Services (HHS) has promised a 60-day notice period to states before the PHE expires, so look for the administration to signal mid-August whether the PHE will renew again in October.

At the same time, the end may be in sight for the ACA subsidies legislated under the 2021 American Rescue Plan Act that served as a healthcare cushion for millions of Americans who became newly insured under the March 2021 pandemic stimulus package. The relief package specified that this support would end at the close of 2022, unless Congress acts to extend it. Some 3.4 million people could lose coverage out of a record 14.5 million ACA enrollees. The impact in terms of uninsured is a bit of a moving target, as some enrollees who are currently covered by one program may become eligible for the other. Some may have gained employer-sponsored coverage in the meantime. Either way, the task of contacting, educating, disenrolling and re-enrolling this many people will be daunting.

CMS Administrator Chiquita Brooks-LaSure said June 22 that “time is of the essence” for Congress to extend ACA subsidies in order to be ready for November Open Enrollment.