ENDING THE PUBLIC HEALTH EMERGENCY: Medicaid Implications for Essential Hospitals

As COVID-19 transitions into an endemic phase, the Biden Administration will end the Public Health Emergency (PHE) declaration, which has been in effect since January 31, 2020. Since the onset of PHE declaration, Medicaid and CHIP enrollment increased by 9.9 million people (13.9%) to a record high of 80 million enrollees.

As a condition of receiving a 6.2% Federal Medical Assistance Percentage (FMAP) increase, the 2020 Families First Coronavirus Response Act (FFCRA) requires states to keep Medicaid beneficiaries enrolled in coverage for the duration of the PHE. However, with the end of the PHE, states will lose the enhanced federal matching funds, balance the loss of the 6.2% FMAP increase, and begin planning for the redetermination process for the approximately 15 million Medicaid enrollees that have retained coverage due to PHE protections. Many of these individuals will need to be transitioned to subsidized coverage and many may also become uninsured.

On March 3, the Centers for Medicare and Medicaid Services (CMS) released State Health Official Letter #22-001 with new guidance for states on providing continuous Medicaid coverage and prioritizing Medicaid eligibility and enrollment workload upon the termination of the PHE.