Kaiser Family Foundation (KFF) researchers said the biggest losses will be among children, adults who became eligible for coverage under the Affordable Care Act’s (ACA) Medicaid expansion, and adults eligible for Medicaid other than due to a disability. These groups experienced the largest increase during the pandemic.
A new KFF analysis finds that between 5.3 million and 14.2 million low-income people could lose Medicaid coverage following the end of the public health emergency and termination of the federal continuous enrollment requirement under the Families First Coronavirus Response Act. The research follows a March issue brief from Urban Institute that estimated as many as 16 million could lose Medicaid coverage after the end of the public health emergency.
The Department of Health and Human Services (HHS) recently renewed the public health emergency to July. It’s unclear whether HHS will extend it once again, but the agency has said it will provide states with 60-days’ notice if it intends to terminate it. The emergency declaration allows providers and health plans to better respond to COVID-19 by taking advantage of flexibilities, including the waiving of telehealth restrictions and cost-sharing for COVID-19 tests. It also allows federal funding to continue to be used for tests, vaccines, and certain treatments for Medicare and Medicaid beneficiaries.
If HHS fails to again extend the public health emergency, the continuous enrollment requirement will end on August 1, and the federal government’s Medicaid match rate for states that meet certain maintenance of eligibility requirements would end on September 30, KFF analysts explained. The continuous enrollment requirement allowed states to be eligible for a 6.2 percentage point bump in the federal Medicaid match rate to help them manage rising enrollment and allow states to reduce state Medicaid spending at a time when states experienced significant drops in revenue early in the pandemic.
Analysts expect state spending on Medicaid to increase following the expiration of the public health emergency and the loss of enhanced federal funding, even after factoring in the expected declines in Medicaid enrollment.
Researchers said they arrived at the estimates of how many people may lose Medicaid coverage after examining two potential scenarios about how states might manage eligibility redeterminations and disenrollments. However, they didn’t study how many of those who lose Medicaid might be able to find coverage from other sources such as the ACA marketplace, how many might become uninsured, and how many might still be eligible for Medicaid but face barriers in retaining coverage.
Based on the analysis, states will have collectively spent $47.2 billion from 2020 through the end of 2022 to cover additional people enrolled in Medicaid because of the continuous enrollment requirement and will have received $100.4 billion in new federal funds to cover those costs and provide general fiscal relief through enhanced Medicaid matching funds.
Researchers estimate that enrollment will grow by 25 percent from 2019 through the end of this year. That would be 22.2 million more people than were enrolled in fiscal 2019 before the pandemic. The increase is due to the continuous enrollment requirement that helped to ensure coverage for enrollees during the pandemic and halted churn or temporary lapses in coverage due to enrollees cycling on and off the program in short periods of time.
It will be up to states to unwind the continuous enrollment requirement, which analysts say could lead to variation in practices and in how many people can maintain their Medicaid coverage. A February KFF survey of state Medicaid directors projected that median Medicaid enrollment would drop by 5 percent in the year following the end of the public health emergency. And a January survey found states expect on average 15 percent of Medicaid beneficiaries will be disenrolled at the end of the continuous enrollment requirement.
Based on these survey results, KFF researchers estimated a 5 percent decline in Medicaid enrollment would translate into a decline of 5.3 million enrollees and a 13 percent decline in Medicaid enrollment would translate into a decline of 14.2 million enrollees. The results show the great deal of uncertainty surrounding how states will implement the end of the continuous enrollment requirement and how many individuals will lose coverage.
Analysts expect the biggest losses to be among adults who became eligible for coverage under the ACA’s Medicaid expansion made eligible for coverage by the Affordable Care Act’s Medicaid expansion, other adults eligible for Medicaid other than due to a disability, and children.