Healthcare groups want advance notice on the end of PHE and Medicaid provisions

MM Curator summary

[MM Curator Summary]: Medicaid industry associations are asking for 90-120 days’ notice for when the PHE ends to help with planning for the eligibility redetermination process.


The article below has been highlighted and summarized by our research team. It is provided here for member convenience as part of our Curator service.


There could be “dangerous and unnecessary gaps in coverage and care,” groups tell Congress.


Photo: SDI Productions/Getty Images


Payer groups are asking Congress for a 90-day notice prior to the end of the public health emergency because of what it means for current Medicaid enrollees who could lose coverage.

Also, Medicaid Health Plans of America and seven other groups want a 120-day notice before the end of federal matching provisions for Medicaid and Children’s Health Insurance Program beneficiaries in the Families First Coronavirus Response Act, which is also related to the end of the PHE.

They sent a letter to Senate and House leaders on February 17 urging Congress to proceed with caution if considering a wind down of the enhanced Federal Matching Assistance Percentage and Maintenance of Effort continuous eligibility provisions. These and other provisions represent significant safeguards that protect Medicaid beneficiaries during the COVID-19 pandemic, the letter said.

If dropped, there could be “dangerous and unnecessary gaps in coverage and care” as states, in coordination with Medicaid health plans, conduct redeterminations on coverage, the groups said.


Medicaid beneficiaries are at risk of losing coverage once the public health emergency ends.

States are required to keep people enrolled in Medicaid throughout the public health emergency as a condition of receiving a temporary increase in the federal share of Medicaid costs, according to The Commonwealth Fund. When the PHE ends, the enhanced federal funding will end and states will resume administering renewals for Medicaid eligibility. 

Medicaid beneficiaries will have their eligibility redetermined, triggering a high risk of coverage losses that is almost certain to fall disproportionately on Black and Latinx individuals who have experienced significant harm and  dislocation during the pandemic, the report said.

Medicaid Health Plans of America said that, throughout the pandemic, Medicaid has provided healthcare coverage and services to more than 80 million low-income, vulnerable people who would otherwise not be able to afford insurance.
“However, we recognize that as the pandemic wears on, the strain placed on the Medicaid program has been building,” the letter said. 

The current public health emergency ends on April 16 and could be extended again by the Secretary of Health and Human Services. It could be allowed to expire at the end of the 90-day period or terminated early if deemed appropriate.

A public health emergency has existed since January 27, 2020. The PHE was renewed four times by former HHS Secretary Alex Azar and has been renewed four times by current Secretary Xavier Becerra.


In an announcement made on February 17, the Centers for Medicare and Medicaid Services said it would seek a Request for Information to develop a more comprehensive access strategy in its Medicaid and CHIP programs.

CMS wants feedback on topics related to healthcare access, such as enrolling in and maintaining coverage, accessing healthcare services and supports and ensuring adequate provider payment rates to encourage provider availability and quality. 

Evidence shows that while Medicaid and CHIP generally provide comprehensive coverage for healthcare services, some enrollees still experience challenges accessing providers and medical services despite statutory access protections in Medicaid, CMS said. 
Interested parties may access the RFI questions and provide comment on The RFI is open for a 60-day public comment period that began February 17.

“We want to hear directly from stakeholders so we can strengthen our programs for the more than 80 million Americans with Medicaid or CHIP health insurance. Together, by advancing health equity, we can ensure quality healthcare is within reach for everyone who needs it,” Becerra said.
“Medicaid and CHIP provide essential health coverage for over 80 million individuals and families,” said CMS Administrator Chiquita Brooks-LaSure. “Ensuring every eligible person can access the coverage and care to which they are entitled is a foundational principle of health equity and our work at CMS. We invite interested stakeholders and individuals with lived experience to join us in this mission, starting by responding to the request for information.”

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