Unwinding of the Medicaid Continuous Enrollment Provision

Author: Stutee Acharya, National Health Corps Member, Legal Council for Health Justice

What is Medicaid continuous coverage

On January 31, 2020, the federal government first declared COVID-19 a Public Health Emergency (PHE). Shortly thereafter, pursuant to the Families First Coronavirus Response Act (FFCRA), Congress gave states extra federal funding to ensure Medicaid customers would not lose coverage during the pandemic unless they requested cancellation, passed away, or moved out of state. This protection is known as the Medicaid Continuous Enrollment provision. As a result, thousands of Illinois residents continued to receive Medicaid throughout the pandemic regardless of eligibility status.

Illinois residents are no longer entitled to this protection. After nearly three years, as part of the Consolidated Appropriations Act of 2022, Congress has set March 31, 2023 as the official end date for continuous Medicaid coverage. Moving forward, states can send out Medicaid redetermination notices and resume Medicaid disenrollments. For Illinois, this process will begin in May, with the first possible loss of coverage for people who no longer qualify being July 1st, 2023.

Important Dates:

• Medicaid continuous enrollment ended 03/31/2023

• Redeterminations for Illinois medical customers will begin 04/01/2023

• The first group of redetermination letters will be mailed on 05/01/2023

• The first date Medicaid customers could lose coverage is on 07/01/2023

What are Medicaid redeterminations?

Medicaid redetermination, or Medicaid renewal, is the process by which the Illinois Department of Healthcare and Family Services (HFS) determines if Medicaid beneficiaries still qualify for coverage. This process was on hold for over two years due to the pandemic, but moving forward, this process will resume occurring every 12 months to redetermine eligibility. In order for this to occur, HFS will mail a Medical Benefits renewal form to each Medicaid member prior to their redetermination date. Members must complete this form by the stated deadline to ensure their benefits will not be terminated.

During the renewal process, the Illinois Department of Healthcare and Family Services (HFS) will look at the following factors:

1. Income: HFS will verify an individual's income by looking at their pay stubs, W-2 forms, and other income-related documents. The state also requires that Medicaid beneficiaries provide proof of income for all household members.

2. Household composition: HFS will review the household composition to ensure that the correct family members are included in the household and that their income is properly counted.

3. Residency: HFS will verify an individual's residency in Illinois to ensure that they meet the program's residency requirements.

4. Citizenship or immigration status: HFS will verify an individual's citizenship or immigration status to determine if they are eligible for Medicaid coverage.

5. Disability status: If an individual is applying for Medicaid based on disability, HFS may review medical records and other documentation to verify the disability.

6. Other eligibility factors: Depending on the individual's circumstances, HFS may also consider other eligibility factors, such as pregnancy, age, and other medical conditions.

It is crucial for Medicaid beneficiaries in Illinois to complete the renewal application and provide all necessary documentation in a timely manner to avoid interruptions in their coverage. The renewal application can be completed online through Manage My Case at abe.illinois.gov, on paper and sent by mail, or by telephone at 1-800-843-6154.

Next steps: Look Out for Redetermination Notices!

On April 1st, 2023, HFS began the redetermination process to determine if Medicaid beneficiaries still qualify for coverage. State Medicaid offices have 12 months to initiate renewals and 14 months to complete them, allowing them to spread out the workload, so not all redeterminations will happen at the same time. Beneficiaries will receive their redetermination letter one month before the renewal form is due and will lose coverage one month after the due date if they do not submit their renewal form or no longer qualify for coverage.

HFS will mail the first batch of redetermination letters on May 1st, 2023. Beneficiaries in this first batch will receive their redetermination form during the first week of May and must submit the form by June 1st, 2023. If they fail to submit in time or are found ineligible, they may lose coverage beginning as early as July 1st, 2023. This process will continue every month for the next 12 months until all renewals are initiated. For example, if Anna receives her redetermination letter during the first week of August, she will have until September 1st to submit her renewal form. If she is unable to submit the form before that deadline, she may lose coverage beginning October 1st.

In addition to Medicaid beneficiaries who have to submit the forms mentioned above, 30-35% of Medicaid customers are automatically renewed for coverage through a process known as Ex Parte or Form A process, by which the Illinois Integrated Eligibility System (IES) reviews any approved electronic sources (ex. reported income for SNAP or SSI eligibility) to verify and process a customer’s eligibility. This process does not require beneficiaries to act; they are sent a notice informing them their coverage has been renewed and are only required to respond if changes need to be reported, such as a change in income or residency. Therefore, whether Medicaid members go through the Form A process or the ex parte process, updating their address is crucial to ensure that HFS does not terminate Medicaid coverage.

Who is at risk for termination?

Resuming determination for Medicaid and Children’s Health Insurance Program (CHIP) put eligible Medicaid members at risk of losing coverage. Populations most at risk for losing Medicaid/CHIP eligibility are (1,2):

• Members who have moved since 2020 (especially if they have not updated their contact information)

• Children

• Young adults between the ages of 18-34

• Beneficiaries with limited English proficiency or disabilities

• People who are not stably housed

According to the Illinois Department of HFS, a federal analysis estimated about 17% of Medicaid customers will lose coverage once redeterminations begin (3). This estimate could mean that around 700,000 Illinois residents could lose healthcare coverage, which is why it is extremely important to urge customers to go to Manage My Case at abe.illinois.gov to verify their address and check their renewal due date.

How can I help my clients?

• Help clients who cannot get through ID proofing get access to Medicaid Managed Care (MMC) so they can check online for redetermination deadlines and their redetermination form. Assist with filling out IL444-3610 (State identity proofing request form) and mailing it to State.

• Encourage clients to update addresses. This address update messaging toolkit contains template messages you can use to encourage clients to call the HFS hotline or visit the web form to update their address. This communications toolkit has information about the steps clients can take to renew their Medicaid or CHIP coverage.

  • The key points to highlight are:

    • Update your contact information at Medicaid.illinois.gov or call 877-805-5312. For TTY, call 877-204-1012.

    • Check your mail for info regarding Medicaid coverage.

    • Complete your renewal form via mail or online at abe.illinois.gov.

    • Connect to coverage at abe.illinois.gov to manage your benefits. If you are no longer eligible, ask your job if they offer health insurance or visit getcoveredillinois.gov to get your own health plan.

• Recommend Medicaid-ineligible clients to transfer to Marketplace coverage. Clients who are no longer Medicaid eligible qualify for Special Enrollment Period (SEP) 60 days before or 60 days after coverage ends (this means they can apply outside of the typical annual open enrollment period).

• Be prepared for different scenarios you may encounter with clients such as:

  • When a Medicaid member has redetermination paperwork but does not know what to do

  • When a Medicaid member does NOT have redetermination paperwork but believe redetermination is due

  • When a Medicaid member does not know when their redetermination is due

This change in Medicaid coverage is no doubt scary to many people, especially those who enrolled during the pandemic and are unfamiliar with the redetermination process that existed before the PHE was declared. During this time, the best way to support clients is to become familiar with the Medicaid unwinding process and spread awareness on how to prepare for the end of continuous coverage so that clients are prepared when the time comes.

Sources

[1] Tolbert, Jennifer, and Meghana Ammula. “10 Things to Know about the Unwinding of the Medicaid Continuous Enrollment Provision.” KFF, April 5, 2023. https://www.kff.org/medicaid/issue-brief/10-things-to-know-about-the-unwinding-of-the-medicaid-continuous-enrollment-provision/.

[2] Artiga, Samantha, Sweta Haldar, Robin Rudowitz, and Anthony Damico. “Unwinding of the PHE: Maintaining Medicaid for People with Limited English Proficiency.” KFF, March 3, 2022. https://www.kff.org/medicaid/issue-brief/unwinding-of-the-phe-maintaining-medicaid-for-people-with-limited-english-proficiency/.

[3]“Illinois Medicaid and the End of Continuous Coverage FAQ.” HFS Illinois Department of Healthcare and Family Services, April 20, 2023. https://hfs.illinois.gov/medicalclients/faqsendofcontinuouscoverage.html.

If you have any questions about the information in this blog post, please contact sacharya@legalcouncil.org.