Marketplace Special Enrollment Period (SEP) - Medicaid Unwinding
The Centers for Medicare & Medicaid Services (CMS) has announced a Marketplace Special Enrollment Period (SEP) for qualified individuals and their families who are losing Medicaid coverage due to the end of the continuous enrollment condition — also known as “unwinding.”*
This temporary SEP, referred to as the Unwinding SEP, will allow individuals and families in Federally-facilitated Marketplace (FFM) states to enroll in Marketplace coverage. CMS will update Marketplace enrollment platforms (HealthCare.gov and Direct Enrollment/Enhanced Direct Enrollment pathways) so that Marketplace-eligible consumers who submit a new application or update an existing application between March 31, 2023, and July 31, 2024, and attest that they have lost or will lose Medicaid or the Children’s Health Insurance Program (CHIP) coverage between these dates, are eligible for the Unwinding SEP. Consumers who are eligible for the Unwinding SEP will have 60 days after they submit their application to select a plan with coverage that starts on the first day of the month after they select a plan.
Many consumers who lose Medicaid coverage will be directed to apply for coverage through the Marketplace. Although the earliest terminations will be effective on April 1, some states began processing unwinding-related renewals on February 1. People who receive advance notice of an April 1 termination may apply for Marketplace coverage 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 CHIPs or the Basic Health Program (BHP), CMS recognizes some states elected to apply certain provisions of section 6008 to their separate CHIP 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.