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Important Update on Medicaid Unwinding


Millions of consumers may soon be eligible for Marketplace coverage. If you or a loved one are impacted by the loss of eligibility, contact AJM Associates for assistance.





Beginning April 1, 2023, states will be able to terminate Medicaid enrollment for individuals who are no longer eligible for coverage. Many consumers who lose Medicaid coverage will be directed to apply for coverage through the Marketplace.

Background: To keep people in coverage during the COVID-19 Public Health Emergency (PHE), under what is known as the “continuous enrollment condition,” states paused terminations for Medicaid coverage as of March 2020.* States would then be required to resume regular eligibility and enrollment operations, including renewals and coverage terminations, when the PHE eventually ended – a process commonly referred to as “Unwinding.”

A recent law provides a date certain for Unwinding to begin.** The “continuous enrollment condition” will now end on March 31, 2023, with states able to begin to terminate Medicaid enrollment for individuals no longer eligible on April 1, 2023. States will then have up to 14 months to complete a renewal for all individuals in their programs. Redeterminations can begin as early as February 1 with the first terminations effective on April 1. People who receive advance notice of an April 1 termination may start enrolling immediately to ensure continuity of coverage.

* Under section 6008(b)(3) of the Families First Coronavirus Response Act (FFCRA), states claiming a temporary 6.2 percentage point increase in the Federal Medical Assistance Percentage (FMAP) have been unable to terminate enrollment for most individuals enrolled in Medicaid as of March 18, 2020, as a condition of receiving the temporary FMAP increase. While the requirements of section 6008 of the FFCRA do not apply to separate the Children's Health Insurance Program (CHIP) or the Basic Health Program (BHP), CMS recognizes some states elected to apply certain provisions of section 6008 to their separate CHIP program or BHP. In those circumstances, subject to exceptions noted and other federal requirements, guidance related to unwinding from the Medicaid continuous enrollment condition also applies to CHIP and BHP.

** On Thursday, December 29, 2022, the Consolidated Appropriations Act, 2023 (CAA, 2023) was enacted. The newly enacted CAA, 2023 does not address the end date of the 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.

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