Last month, my colleagues and I at the Michigan League for Public Policy completed a memo to the Michigan Department of Health and Human Services regarding the forthcoming expiration of the federal public health emergency (PHE), and, with it, its continuous coverage requirement.

While the PHE is now extended until mid-October, health coverage for millions of people — including here in Michigan — could be in jeopardy when the PHE ends and states resume their regular eligibility reviews of all Medicaid enrollees.

Here is a brief rundown of what the PHE has to do with continuous Medicaid and Children’s Health Insurance Program coverage and what the League has shared with DHHS as it prepares for the task of unwinding come fall.

In March 2020, Congress provided that state Medicaid programs would receive increased federal funding if states did not disenroll any Medicaid beneficiary. In other words, all Medicaid/CHIP beneficiaries have benefitted from uninterrupted coverage since the start of the COVID-19 pandemic.

With the public health emergency expected to expire this fall, along with its associated enhanced federal support, state Medicaid agencies across the country are tasked with developing an approach to unwinding the continuous coverage requirement in their state and redetermining eligibility for every single one of its Medicaid/CHIP beneficiaries.

The volume of work facing state Medicaid agencies is significant, as is the gravity of conducting such an undertaking thoughtfully. Coverage continuity is incredibly valuable, and even small administrative hurdles may prevent eligible individuals from successfully completing a Medicaid renewal application.

Therefore, our hope is that the state is planning for robust outreach to beneficiaries and partnerships with health plans, community-based organizations, health care navigator groups, and other interested stakeholders to help prevent administrative denials and to connect those who are ineligible for Medicaid or CHIP to alternative coverage.

The League’s recommendations for policymakers and administrative officials related to the continuous coverage expiration include:

∫ Planning for a 12-month unwinding period to process renewals after the PHE ends;

∫ Considering a process for engaging local partners and stakeholders interested in helping to shape Michigan’s unwinding plan;

∫ Sharing the state’s official plan for resuming routine Medicaid/CHIP renewal operations;

∫ Partnering with Medicaid managed care organizations and community-based organizations to ensure effective communication with beneficiaries;

∫ Increasing the percentage of Medicaid/CHIP renewals completed ex parte;

∫ Continuing to allow Medicaid/CHIP beneficiaries to renew online, in-person, or by phone;

∫ Investing in current and new staff to assist beneficiaries with the renewal process;

∫ Making state call center statistics publicly available;

∫ Stratifying disenrollment data by “Ineligibility Established” and “Eligibility Could Not be Established”; and

∫ Expanding follow-up methods for harder-to-reach beneficiaries.

Saying things like “resuming normal Medicaid renewal operations” can feel cold and devoid of humanness. But Medicaid isn’t devoid of humanness. It’s a program made up of individuals, families, and children.

It’s about allowing entry to necessary care.

It’s about people, ultimately.

The PHE’s extension is not only a relief for Medicaid enrollees and DHHS workers — it is an opportunity. We know Michigan officials are working hard to prepare for the PHE transition and protect coverage for millions of Michiganders, and these are concrete steps that can be taken to assist with that effort.

Amber Bellazaire is a policy analyst at the Michigan League for Public Policy.