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October 20, 2022 (Cleveland, OH)

HHS Extends Public Health Emergency, CMS Issues FAQs on Medicaid Unwinding



Shortly following the U.S. Department of Health and Human Services’ (HHS) most recent extension of the current COVID-19 public health emergency (PHE), the Centers for Medicare and Medicaid Services (CMS) released a set of frequently asked questions (FAQs) to help states prepare for the eventual end of the PHE, particularly as it impacts Medicaid coverage.

On Oct. 13, HHS Secretary Xavier Becerra signed a renewal of the PHE, extending it for an additional 90 days into mid-January. The PHE originally went into effect on Jan. 31, 2020, and what followed were a number of policy changes, including temporary expansions in telehealth and Medicaid eligibility.

Under the PHE, states have been receiving a 6.2% increase in the federal medical assistance percentage (FMAP), which is essentially the federal share of Medicaid expenses, as long as they have met certain conditions. These include providing continuous eligibility for individuals who were enrolled in Medicaid on or after March 18, 2020.

Given the complexities involved with an ending of the PHE, the Biden Administration has committed to providing 60 days’ notice in advance of allowing the PHE to expire.

On Oct. 17, CMS released a set of FAQs aimed at clarifying aspects of the guidance they issued in March. According to the FAQs, states may begin the process of Medicaid unwinding in the month preceding, the month of, or the month following the end of the PHE. Regardless of when they choose to do so during this time period, if they continue to claim the enhanced FMAP they may not terminate enrollment until the first day of the month after the month in which the PHE ends.

The FAQ also covers certain specifics related to renewals or changes in circumstance, Section 1902(e)(14)(A) waivers, immigration status and citizenship, suspension and resuming of premiums, data reporting and other topics.

In Ohio, the Department of Medicaid is expected to provide additional guidance, including a toolkit, for partner organizations to use during the unwinding to support consistent communication.

Additional resources on the Medicaid unwinding also are available at Medicaid.gov.