Whew! HHS Sec. Becerra extends PHE thru 10/13, pushing back a potential Medicaid disenrollment crisis


As I (and many others) have been noting for many months now, the official end of the federal Public Health Emergency (PHE), whenever it happens, will presumably bring with it reason to celebrate...but will also likely create a new disaster at the same time:

What goes up usually goes back down eventually, and that's likely to be the case with Medicaid enrollment as soon as the public health crisis formally ends...whenever that may be.

Well, yesterday Ryan Levi and Dan Gorenstein of of the Tradeoffs healthcare policy podcast posted a new episode which attempts to dig into just when that might be, how many people could be kicked off of the program once that time comes and how to mitigate the fallout (I should note that they actually reference my own estimate in the program notes):

In March 2020, Congress offered states additional Medicaid funding as long as they agreed to keep everyone enrolled in the program for the duration of the federal public health emergency, regardless of their eligibility status. As of January 2021, nearly 10 million had joined Medicaid or the Children’s Health Insurance Program (CHIP) during the pandemic, pushing enrollment to a record high of more than 80 million people. (Some independent analyses put the current total higher, closer to 90 million.)

The Biden administration has indicated the public health emergency will last at least through the end of 2021. Once it expires, states will once again be required to remove ineligible people from their rolls. While no national estimates exist for how many people currently enrolled in Medicaid are technically ineligible, a Tradeoffs survey of state Medicaid offices found that just nine states expect an estimated 1,450,877 of their current beneficiaries are ineligible and would lose coverage once the health emergency ends (see table below).

This suggests that nationwide, millions are likely to lose their coverage, which is in line with expert expectations that much of Medicaid’s growth during the pandemic is a result of the continuous enrollment requirements.

Last September, an analysis by Matthew Buettgens of the Urban Institute estimated that perhaps 15 million current Medicaid enrollees could be kicked off of the program as soon as the PHE officially ends...

Medicaid enrollment has risen substantially since the start of the COVID-19 pandemic. Recent data show enrollment jumped by more than 9 million people from February 2020 to January 2021. The higher enrollment is driven by two main causes: the unprecedented pandemic-related job losses concentrated in March to June of 2020 and the continuous coverage requirement of the Families First Coronavirus Response Act, which prohibits state Medicaid agencies from disenrolling beneficiaries during the public health emergency (PHE). Even as the economy improves, however, the continuous coverage provision is likely to contribute to even higher Medicaid enrollment through 2021. We estimate that by the end of 2021, 17 million more nonelderly people will be enrolled in Medicaid than before the pandemic, and we estimate that the number of Medicaid enrollees could decline by about 15 million people in during 2022 after the public health emergency is expected to expire.

...which would cause chaos, confusion and a massive backlog at various state and federal agencies if it happened all in one shot.

The good news is that a few days ago HHS Secretary Becerra officially declared another 90-day extension:

Renewal of De​​termination That A Public Health Emergency Exists

As a result of the continued consequences of the Coronavirus Disease 2019 (COVID-19)  pandemic, on this date and after consultation with public health officials as necessary, I, Xavier Becerra, Secr​etary of Health and Human Services, pursuant to the authority vested in me under section 319 of the Public Health Service Act, do hereby renew, effective July 15, 2022, the January 31, 2020, determination by former Secretary Alex M. Azar II, that he previously renewed on April 21, 2020, July 23, 2020, October 2, 2020, and January 7, 2021, and that I renewed on April 15, 2021, July 19, 2021, October 15, 2021, January 14, 2022, and April 12, 2022, that a public health emergency exists and has existed since January 27, 2020, nationwide. ​

July 15, 2022​

​Xavier Becerra

This means that the federal Public Health Emergency declaration is still in place through at least October 13, 2022...which also means that the Medicaid continuous coverage provisions will remain in place until at least November 1st, and I believe it also means the extra federal Medicaid funding states receive will stay in place until at least the end of 2022.