ANTM reaffirmed guidance this week even though it includes an April end to the Public Health Emergency which clearly will not happen. Their guide also assumes Medicaid redeterminations will begin mid-year. As things stand today, the Public Health Emergency is scheduled to end in mid-July but it might take longer as CMS develops guidance for states and fields a million questions. A 3Q or 4Q end is not out of the question.
CMS guidance thus far permits states to begin sending redetermination notices 60 days prior to the end of the PHE. The White House has promised to give everyone a 60 day heads and states are getting ready to begin the redetermination process.
If we assume the PHE will end in July, which given the White House pledge of a heads up, is the earliest possible date at this point, redeterminations can indeed begin about mid-year ~ May 15. Using that same schedule the enhanced FMAP that supports the potentially ineligible beneficiaries will terminate at the end of 3Q 2022. Also important to note, CMS is requiring redetermination of the entire 83 million enrollees not just those who were added during the PHE.
The first set of redetermination notices will be based on electronic data matches through tax returns and other datasets that can verify income without a discussion with the enrolled individual. Conversations with former Medicaid officials suggests about half of redeterminations would be complete about the 12 month mark or around May 2023. It will probably take another year to complete the rest. Redetermination are subject to appeals and notice requirements that can bog the process down significantly. All the while, there is no additional federal money to support the ineligible enrollees.
States are swimming in cash from COVID relief so they may be able to support the extra enrollment for a while after the FMAP ends. The longer the redetermination process drags on, however, the more risk to plan sponsors from state budget pressures.
For another day: conversion of ineligible Medicaid enrollees to exchange plans won't be that easy either. We will see if we can come up with a chart for that.
Let me know if you have any questions.
Emily Evans
Managing Director – Health Policy
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