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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, 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