Unwinding and Returning to Regular Operations after COVID-19   

Posted in COVID-19, Senior Living

Mary Madison, RN, RAC-CT, CDP
Clinical Consultant – Briggs Healthcare

Before you get anxious, thinking that this blog is announcing the end of the PHE – it’s not.  The PHE declaration is still in place as evidenced by the January 5, 2023 CMCS Informational Bulletin: Key Dates Related to the Medicaid Continuous Enrollment Condition.  Towards the end of the 1st paragraph of this bulletin, you’ll find this statement: “The newly enacted CAA (Consolidated Appropriations Act), 2023 does not address the end date of the COVID-19 Public Health Emergency (PHE), and as of January 2023, the PHE is still in effect; it does, however, address the end of the continuous enrollment condition, the temporary FMAP increase, and the unwinding process.”  Please also remember that CMS promised to provide at least 60 days- notice before the PHE declaration expires and that 60-day notice has not materialized.  The renewal in October 2022 is “up again” later next week.  In this blog, I’m providing an FYI document: Unwinding and Returning to Regular Operations after COVID-19.

Today (January 6, 2023), the Centers for Medicare & Medicaid Services (CMS) released a document that provides detailed description of the configuration/implementation plan, testing plan, and testing results that states will need to submit when the public health emergency (PHE) and continuous enrollment condition end. This document aims help states understand systems readiness artifacts that are routinely submitted to CMS’ State Systems team during IT project and certification reviews. This release includes an FAQ, and also  points to previously released systems guidance (Streamlined Certification Guidance, Testing and Automation resources, etc.).

The expiration of the continuous coverage requirement authorized by the Families First Coronavirus Response Act (FFCRA) presents the single largest health coverage transition event since the first open enrollment period of the Affordable Care Act. As a condition of receiving a temporary 6.2 percentage point Federal Medical Assistance Percentage (FMAP) increase under the FFCRA, states have been required to maintain enrollment of nearly all Medicaid enrollees. When the continuous coverage requirement expires, states will have up to 12 months to return to normal eligibility and enrollment operations.

Additionally, many other temporary authorities adopted by states during the COVID-19 public health emergency (PHE), including Section 1135 waivers and disaster relief state plan amendments (SPAs), will expire at the end of the PHE, and states will need to plan for a return to regular operations across their programs. CMS will continue to update this page as additional tools and resources are released.