Once again, the Biden Administration has renewed the COVID-19 Public Health Emergency (PHE), marking the 12th extension since it was first declared at the outset of the pandemic to make it easier for millions of Americans to access critically important health programs. While many are speculating that this may be one of the final extensions of the PHE, the recent federal decision to phase out the continuous coverage requirement come April 1, 2023, puts states in a position to quickly transition some of the country’s most vulnerable populations to alternate sources of health insurance coverage. 

Why will redeterminations begin before PHE ends? 

Since its declaration, the PHE has ensured that millions of Americans receive health insurance coverage, especially those who rely on Medicaid whose coverage has been safeguarded by the PHE. However, the newly passed federal government spending law removed a number of core measures of the PHE. One of which is the continuous coverage measure – a requirement that prevents states from redetermining the eligibility of Medicaid recipients. This means that on April 1, regardless of whether the PHE is still in place or not, states will be set to start Medicaid redeterminations.  

What is at stake during the redetermination process? 

Through the redetermination process, an estimated 18 million Americans are at risk of losing their health insurance as gaps in coverage emerge. States have a range of preparedness levels when it comes to processing Medicaid redeterminations depending on their capacity and quality of data. Many who lose coverage as a result of the continuous coverage requirement being removed are still eligible for coverage, such as Affordable Care Act (ACA) plans available through Healthcare.gov and State-Based Exchanges.  

What can State-Based Exchanges do?  

Regardless of the fate of the COVID-19 Public Health Emergency, states need to be prepared for the end of the continuous coverage measure come April 1 when they will need to begin processing Medicaid redeterminations. This means states should be assessing staff capacity and analyzing data to effectively plan for the redeterminations. No American should go without health insurance when there are options available to them. States need to use this time wisely to prepare for the massive shifts in coverage that will inevitably occur when these redeterminations resume. Luckily, GetInsured client states already have the infrastructure and technology in place to best manage such a shift.