On March 28, 2024, the U.S. Division of Well being and Human Companies (HHS), by way of the Facilities for Medicare & Medicaid Companies (CMS), introduced that it’s extending the momentary particular enrollment interval (the Unwinding SEP) for prior beneficiaries of Medicaid and Medicaid-expansion Kids’s Well being Insurance coverage Applications (CHIP) to enroll within the Well being Insurance coverage Market (Market). The Unwinding SEP was beforehand scheduled to terminate on July 31, 2024, however now the tip date is prolonged to November 30, 2024. This 4-month extension will assist hundreds of thousands keep insurance coverage protection as they navigate their new post-pandemic eligibility statuses.
Moreover, on April 2, 2024, CMS launched Half 2 of a complementary Closing Rule on Streamlining the Medicaid, CHIP, and Primary Well being Program Software, Eligibility Dedication, Enrollment, and Renewal Processes. Whereas the Unwinding SEP extension helps guarantee protection continuity for these just lately ineligible for Medicaid and CHIP, the Closing Rule does the identical for many who are nonetheless Medicaid or CHIP eligible. The Closing Rule takes impact on June 3, 2024.
The COVID-19 Steady Enrollment Requirement
Earlier than the pandemic, state Medicaid companies performed yearly eligibility critiques of Medicaid and CHIP enrollees and have been permitted to disenroll ineligible people. Throughout the COVID-19 pandemic, within the spring of 2020, Congress enacted the Households First Coronavirus Response Act (FFCRA), which paused this eligibility evaluate course of and prohibited state Medicaid companies from involuntarily disenrolling beneficiaries or transferring enrollees to a distinct protection group that gives a extra restrictive profit package deal. Medicaid and Medicaid-expansion CHIP packages have been required to keep up steady enrollment for all beneficiaries by way of the length of the COVID-19 public well being emergency (PHE) in trade for enhanced federal funding. This requirement protected protection for beneficiaries whose circumstances modified such that they have been now not historically eligible for Medicaid or CHIP.
Mass Disenrollment and the Unwinding SEP
The PHE ended within the spring of 2023, and the 2023 Consolidated Appropriations Act ended the Medicaid and CHIP steady enrollment requirement on March 31, 2023. The termination of this requirement successfully resumed the pre-pandemic established order, allowing states to abruptly disenroll Medicare and CHIP beneficiaries. This mass-disenrollment occasion “current[ed] the single largest well being protection transition occasion for the reason that first open enrollment interval of the Reasonably priced Care Act.” Roughly 15 million people (17.4% of all Medicaid and CHIP beneficiaries) grew to become in danger for lack of medical health insurance protection. Disenrollment from Medicaid and CHIP packages has been occurring since final March on a rolling foundation, catching off-guard beneficiaries who had been beforehand assured protection for years and leading to insurance coverage protection disruptions.
To mitigate these insurance coverage protection disruptions, in January of 2023, CMS created the Unwinding SEP, allowing just lately disenrolled Medicaid and CHIP beneficiaries to enroll in a Market plan outdoors of the conventional open enrollment window. The Market is a government-run portal the place people who should not eligible for Medicaid or CHIP and who shouldn’t have employer-based insurance coverage can examine and enroll in reasonably priced insurance coverage insurance policies. The usual open enrollment interval for the Market is November 1 to December 15, so with out this Unwinding SEP, people who have been disenrolled from Medicaid and CHIP outdoors of this window would have lacked the chance to keep up reasonably priced protection within the interval between their disenrollment and the usual Market open enrollment interval. The Unwinding SEP initially opened Market enrollment from March 31, 2023 by way of July 31, 2024.
2024 Unwinding SEP Extension
Now, the Unwinding SEP has been prolonged by way of November 30, 2024. This extension will assist these just lately excluded from Medicaid or CHIP to promptly safe reasonably priced, complete protection by way of the beginning of the following open enrollment interval. People who’re just lately non-Medicaid/CHIP-eligible however are Market-eligible can apply for insurance coverage anytime throughout the prolonged Unwinding SEP at HealthCare.gov.
Complementary Closing Rule: Streamlining Medicaid and CHIP Enrollment and Renewal
Hand-in-hand with the Unwinding SEP extension, which is geared toward safeguarding protection for these just lately ineligible for Medicaid or CHIP, is the Closing Rule, which establishes a number of measures to safeguard protection for these nonetheless eligible for Medicaid or CHIP. The Closing Rule endeavors to lower the executive boundaries to Medicaid and CHIP enrollment and renewal, particularly by:
- Prohibiting states from requiring in-person interviews for these whose eligibility relies on having a incapacity or being no less than 65 years outdated;
- Permitting flexibility for beneficiaries with a incapacity or who’re 65+ to resume protection by way of cellphone, mail, in-person, or on-line;
- Eradicating the choice for states to impose a “Lock-Out Interval,” which quickly blocked households from re-enrolling after a missed CHIP premium fee;
- Requiring Medicaid companies to test sure classes of accessible knowledge previous to terminating enrollment when beneficiaries can’t be reached by way of mail; and
- Requiring Medicaid companies to supply potential beneficiaries no less than 15 calendar days to return supplemental info requests in reference to an utility, and 30 calendar days to return info in reference to a renewal.
Conclusion
Each CMS’s extension of the Unwinding SEP and publication of the Closing Rule increase upon its efforts over the previous yr to guard insurance coverage protection for hundreds of thousands throughout the post-PHE transition interval. For extra details about the Closing Rule’s changes to the Medicaid and CHIP enrollment and retention processes, see the Closing Rule Reality Sheet.
