February 16, 2023

End of Continuous Coverage and What That Means for Medicaid in Florida

In January 2020, the Secretary of Health and Human Services (HHS) declared a COVID-19 public health emergency (PHE). During this time, Floridians enrolled in Medicaid and the Children’s Health Insurance Program (CHIP) were able to keep their coverage without having to re-enroll, a rule referred to as “continuous coverage.” On December 29, 2022, President Biden signed into law the Consolidated Appropriations Act 2023, which declared the Continuous Coverage provision of Medicaid to officially end on March 31, 2023.

Now, beginning on April 1, 2023, Florida’s Department of Children and Families (DCF) will start disenrolling Medicaid recipients who are no longer eligible for their health insurance plans due to income changes that happened between 2020 and 2023. This disenrollment is set to be the single largest health coverage transition event since the first open enrollment period of the 2010 Patient Protection and Affordable Care Act.

A previous blog highlighted the fact that many of the 5.5 million Floridians who receive Medicaid would face barriers to maintaining their health care coverage once this provision ended, and stated that it would be important for the state of Florida to streamline this process by releasing a detailed plan that would follow some mandatory and further optional guidance required by the National Centers for Medicaid And Medicare Services.  Additionally, Florida Policy Institute and Florida Health Justice Project curated a statewide sign-on letter urging Governor DeSantis to release these plans.

Thanks to the calls of many advocates, DCF released their plans for how the state will begin disenrolling those who are no longer eligible for Medicaid in mid-January.

How Does the Plan Address the 2022 Concerns and Streamline Eligibility and Enrollment?

Renewal and Eligibility Notices

Advocates previously expressed concern that the renewal and eligibility notices DCF mailed out before the COVID-19 pandemic were difficult to understand. In addition, individuals stated that these notices often felt threatening, were too long, and that the language was not clear.  Yet, DCF’s plan for notifying Floridians about disenrollment decisions does not include upgrading these notices to make them understandable and less intimidating.

Modes for Submitting Applications

DCF has noted that the main method of applying for Medicaid and other related services will continue to be done through the ACCESS portal online. There is still not a mobile-friendly version of this site, so individuals who need to apply via cell phone or tablet may face barriers. Additionally, individuals may file a paper application via fax, mail, or in person at the department’s customer service centers or through community partner sites around the state.

Ex-Parte Renewals

Most states use a process called ex-parte renewal that utilizes data-matching to automatically determine whether individuals are still eligible for Medicaid, and automatically renew their benefits if they still meet the income limits. This is beneficial because those who are given an ex-parte renewal do not have to reapply. Since FPI’s last blog post, DCF reports that they have improved their technology, and this has increased the percentage of ex-parte renewals from 25 percent as previously reported to 67 percent. This is good news.

Medicaid Renewal Communications

Even though the ex-parte process has been improved, there are still around 2 million people in Florida who will need to submit renewals to DCF, and many of these individuals who started only receiving Medicaid at the beginning of the pandemic have not gone through this process before. DCF has improved their process of contacting those who need to renew since FPI’s last blog post. Most importantly, DCF has expanded their outreach efforts by increasing the number of ways they will contact enrollees. Specifically, they have gone from only contacting via mail or email to include text messaging those who need to renew. This can help mitigate the loss of coverage for people who remain eligible yet have changed physical addresses.

In terms of reaching out to individuals who may have moved during the pandemic, DCF states that there are continuous efforts between the department and vendor staff to actively confirm the addresses of individuals who are enrolled. Additionally, DCF will provide outreach materials to the Agency for Healthcare Administration (AHCA) that will then go to the health plans that provide Medicaid services. These outreach materials will be used to assist individuals with changing their addresses and updating their contact information.

Increasing Staffing

According to a Kaiser Family Foundation and Georgetown University 50-State survey, many state agencies expressed concerns about the capacity and staffing needed to successfully complete eligibility renewals at the end of the PHE. During the time of the survey and before the plans were released, Florida had planned to increase the number of staff who could assist with determining eligibility for Medicaid enrollees by approving overtime, hiring new workers, borrowing from other staff agencies, and hiring contractors.

The current plans do not have specific details about the implementation of the previous stated plans or how many individuals it seeks to hire, but the agency has stated that it has “implemented strategies to maintain its workforce to support the increase in Medicaid redeterminations when the continuous coverage period ends.” These plans include:

▪︎ Streamlining hiring practices to reduce time to fill positions.

▪︎ Providing overtime during the PHE to promote timely case processing.

▪︎ Enhancing call center performance by onboarding additional call center agents to provide support for individuals and hiring vendor staff to assist with overflow call volume.

Areas of Concern

The state has highlighted that there are already 900,000 cases (some of which may have more than one individual) who have been declared ineligible for Medicaid. As a state that has not expanded its Medicaid program, it is unclear how many of these new individuals will fall into the coverage gap and no longer have health insurance.

It is too soon to tell whether these plans will be enough to ensure a “successful” beginning to a new redetermination process. The state will be federally required to report data on this process, and it is in the best interest of the state of Florida to be transparent and timely with this data so that advocates and organizations can troubleshoot areas of arising concern.

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