Ever since the Public Health Emergency (PHE) was extended for the ninth time – to July 15th – there was growing speculation that the Biden Administration would not extend the PHE past the July 15th date. However, this turned out not to be the case.   

There are plenty of reasons ending the PHE is a hard call, ranging from political concerns to fears of a winter COVID spike. There are also several healthcare-related measures tied to the PHE, ranging from free COVID tests and extensions of COBRA and HIPAA deadlines to the expanded use of telehealth and certain waivers under various public health programs. But the most impactful health care-related measure tied to the PHE is Medicaid coverage. And that’s the issue we’ve been tracking. Why? 

Until the PHE ends, States can access increased Federal funds if the States did not – and do not – question a person’s eligibility for Medicaid. But once the PHE ends, States are required to re-start their “eligibility determinations,” and on account of “re-determinations” for those individuals currently enrolled in Medicaid, a great number of these individuals (reports indicate up to 16 million) will no longer be eligible for Medicaid due to changes in income or other circumstances. They will then have to (1) find health coverage elsewhere or (2) go without insurance. With the enhanced subsidies for Qualified Health Plans (QHPs) – originally provided by ARPA – still set to expire at the end of the year, affordability of coverage is a big concern for these individuals who will be redetermined out of Medicaid.  

To help ease the burden on both states and consumers, the Biden Administration has given States 12 additional months after the end of the PHE to “re-determine” people’s Medicaid eligibility. As a result, most of the now-Medicaid eligible individuals will continue to have coverage for at least a period of time after the PHE ends. This provides a much-needed cushion and ensures that there will not be a loss of coverage all at once. 

An “official” extension of the PHE won’t be announced until we get closer to July 15th, but that announcement is coming. There is also a very good chance that the PHE will continue to be extended through January 2023. Time will tell.