States begin Medicaid disenrollment
In 2020 (we don’t have to tell you what was going on in 2020, do we?), Congress passed the Families First Coronavirus Response Act (FFCRA), which essentially stopped states from disenrolling people from state-run Medicaid and Children’s Health Insurance Program (CHIP) benefits. Thanks to the Consolidated Appropriations Act that Congress signed in the last few days of 2022, the requirement has ended effective in April 2023.
People can be disqualified from Medicaid or CHIP for a number of reasons, most of them related to work and income requirements that vary by state, and Medicaid “churn” – people disenrolling and re-enrolling weeks, months, or even just a year later – is high. In fact, in any given month, 10 percent of Medicaid enrollees are people who have previously been on Medicaid but were disenrolled for a few months because of a temporary increase in income. Much of the time, people who are disenrolled and who then re-enroll just go without health care insurance in the meantime. Another fact: The people who are most likely to experience Medicaid and CHIP program churn are seniors and children.
The Kaiser Family Foundation (KFF) has an excellent brief of what disenrollment might look like, or, as KFF calls it, “the Unwinding of the Medicaid Continuous Enrollment Provision.” The summary: Anywhere from 5 million to 15 million people may be unenrolled over the next several months, many of them will be “churn” enrollees, and generally the net result will be fewer Americans with insurance coverage at any given time. Put another way, many of the people the states will disenroll from their Medicaid programs won’t get insurance through other means.
Delaware issued a bulletin to enact a Special Enrollment Period (SEP) for the approximately 40,000 Delaware residents the state anticipates disenrolling from Medicaid. These individuals will have 60 days from their disenrollment notice to select a Health Insurance Marketplace plan or request enrollment in any employer-based coverage they can access.
The bulletin also opens a Medicare Supplement (also known as Medigap) SEP for Delawareans who qualify to enroll in Original Medicare, allowing them to enroll in gap or supplemental plans without underwriting restrictions. People with disabilities or who are 65 and over can use this SEP, and the state requests health insurers to offer a guaranteed issue period for people who qualify for 63 days from the date the state removes their Medicaid eligibility.
Oklahoma announced similar provisions for the state’s SoonerCare disenrollment. The Oklahoma Health Care Authority will send four letters to disenrolled Oklahomans, one to remind them of renewal season, a second letter to tell them if their coverage is ending and when and why, a third at 45 days from their coverage end, and a fourth 10 days before their coverage ends.
Like Delawareans, Oklahomans will have 60 days from ineligibility to find alternative coverage.
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