The End of the COVID-19 Public Health Emergency: Preparing for the Medicare Impact - Western Asset Protection

The End of the COVID-19 Public Health Emergency: Preparing for the Medicare Impact

The COVID-19 public health emergency may be ending soon. When this happens, many people are likely to lose their Medicaid coverage. For millions of dually eligible Medicare enrollees, this could mean new renewal requirements and may necessitate a plan switch.

When Will the Public Health Emergency End?

COVID-19 is still spreading. Plus, new variants may increase the risk of infection and re-infection. However, the CDC says deaths from COVID-19 have substantially decreased in the U.S., due to both increased immunity and improved treatments.

The public health emergency has been in effect since January 27, 2020. Since then, it has been renewed multiple times, most recently on October 13, 2022.

Although additional renewals are possible, there may not be many more. According to KFF, state Medicaid officials expect an official end to the COVID-19 public health emergency sometime in 2023.

The Impact on Medicaid

The end of the public health emergency will mean the end of temporary pandemic-related federal funding for state Medicaid programs, which is expected to have a significant impact on Medicaid spending.

There is also likely to be an impact on enrollment. KFF explains that one of the provisions in the Families First Coronavirus Response Act established a continuous enrollment requirement for Medicaid. To receive the enhanced federal funding, Medicaid programs have had to keep people continuously enrolled through the end of the month in which the public health emergency ends.

Normally, people can lose Medicaid coverage because they are no longer eligible – for example, if their income increases or they fail to complete the necessary paperwork to prove they still qualify. During the pandemic, many people who might have been disenrolled in normal circumstances were able to keep coverage. Medicaid enrollment has surged, but KFF expects this trend will reverse following the end of the public health emergency, when millions of people could lose coverage.

How Many Medicare Enrollees Are Also in Medicaid?

Medicare and Medicaid are separate programs with different eligibility requirements, but many seniors are eligible for both. According to the Medicaid and CHIP Payment Access Commission (MACPAC), there were 12.2 million dually eligible beneficiaries as of the calendar year 2019 and 62% were aged 65 or above. Nearly one in five Medicare enrollees is dually eligible.

To simplify care coordination, many dually eligible beneficiaries enroll in a Dual Eligible Special Needs Plan (D-SNP). MACPAC says there were approximately 3.8 million beneficiaries enrolled in D-SNPs as of February 2022.

What Will Happen to Dually Eligible Enrollees?

When Medicare D-SNP enrollees lose Medicaid eligibility, they are disenrolled from their plan. According to Medicare, there is a grace period of at least one month and some plans may provide longer grace periods. If the beneficiary regains Medicaid eligibility during this grace period, they may be able to stay in the plan. If they do not regain eligibility, they will be disenrolled.

Beneficiaries who are disenrolled from their D-SNP are given a Special Enrollment Period (SEP) to select a new Medicare plan. The SEP starts when the plan notifies beneficiaries they are no longer eligible, continues through the grace period, and ends two months after coverage ends.

Help Your Clients Navigate This Change

When the public health emergency ends, many D-SNP enrollees may be caught off guard by the renewal requirements.

  • Watch out for the official end of the public health emergency. When it is announced, give your clients a heads-up.
  • Share information on the renewal process. Arizona’s Medicaid agency is the Arizona Health Care Cost Containment System (AHCCCS). In some cases, the AHCCCS renewal process does not require action from the beneficiary, but sometimes a response is necessary. See the AHCCCS Renewal Processes page for more information.
  • Be ready to help your clients with plan changes. You may see an increase in Medicare clients who need to switch plans during a Special Enrollment Period. Medicare plan providers will be preparing for this – and you should, too.

The end of the COVID-19 public health emergency could be disruptive for dually eligible Medicare enrollees. If you have any questions or need assistance, Western Asset Protection is here to help. Contact us.