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  • Sharon R. Williams

Changes in Medicaid: COVID-era Expanded Eligibility Ends & Disenrollment Reviews Begin Again

In 2020, the COVID-19 pandemic quickly overwhelmed U.S. and global health care systems. In response to this looming public health crisis, the federal government enacted Public Health Emergency regulations. Declaration of a national PHE means these regulations can override existing rules if they are deemed to restrict the ability to provide care. In addition, the government eases access to funding, resources and other services and supports, all to increase availability of critically needed care. Generally, PHE declarations are effective for 90 days, however, the critical and ongoing nature of the COVID-19 pandemic led to multiple extensions. A recent announcement from the Biden administration means the benefits provided under this declaration will soon end – some in April and others the following month.

The federal government also enacted regulations to support individual states in facilitating COVID-19 care and treatment, such as the Families First Coronavirus Response Act. This legislation funded states so they could provide free vaccines and other COVID-19 emergency services. It also provided additional funding and required states accepting that funding to maintain continuous enrollment of Medicaid beneficiaries through the PHE.

Key provisions of the COVID-19 PHE waivers allowed states to also expand emergency Medicaid insurance and therefore provide coverage to people who might not otherwise meet standard Medicaid eligibility rules. This meant that some 15,000,000 – 18,000,000 people qualified for Medicaid insurance under the PHE and FFCRA provisions, when they otherwise might not have been eligible, including many older adults and caregivers.

Under the FFCRA, states also deferred routine Medicaid eligibility redetermination reviews and suspended disenrollments, resulting in continuous enrollment for beneficiaries. But this pause on eligibility reviews and suspensions is now coming to an end. The Biden administration recently announced that starting April 1, states can resume Medicaid redeterminations and disenroll beneficiaries who do not qualify under pre-pandemic eligibility guidelines. States may take up to 14 months to complete this process.

Further, the COVID-19 PHE will end on May 11, halting federal emergency funding to states to support some COVID-19 expanded services and supports. A federal agency, the Centers for Medicare and Medicaid Services, is working with states to transition COVID-19 related healthcare and insurance services back to pre-pandemic levels. This may mean termination of Medicaid insurance for many of those who qualified under the PHE, an estimated 15,000,000 people, according to the US Department of Health and Human Services.

A recent Urban Institute survey reported that 64% of the adults on Medicaid are not aware of the potential impact of the end of the PHE on their insurance coverage, with the looming return to pre-pandemic Medicaid re-determination processes. States are required to provide an orderly eligibility review process and to assist those who may qualify for other coverage, perhaps via Affordable Care Act insurance options. The Michigan Department of Health and Human Services has posted beneficiary assistance information on its website at:

To ensure being alerted of any possible Medicaid benefit changes, beneficiaries should make sure their contact information, including mailing address, phone number and email address, is updated. Contact your local MDHHS office, visit, or call the state health department at 855.789.5610.

Those who are on Medicare should also take note of another emergency provision that will sunset. Under the PHE, the government covered eight free over-the-counter COVID-19 rapid test kits per month for Medicare beneficiaries. Medicare Advantage Plans may continue to offer some free or low-cost access to these OTC COVID-19 tests. Each plan can choose how to administer this benefit, enrollees should contact their plan's customer service line for more information. After May 11, access to free government sponsored OTC COVID-19 rapid test kits may no longer be available to beneficiaries who are not enrolled in a Medicare Advantage Plan.

Sharon Williams is an enterprising leader in the health care and community-based services industries. She has led transformative initiatives with the Senior Resource Center, SE MI; Detroit Area Agency on Aging; and the NCOA-Aging Mastery Program. She is the CEO of Williams Jaxon Consulting, LLC and can be reached at:

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