October 14, 2022

Florida’s Medicaid "Continuous Coverage" is Still in Effect

Since March 2020, there has been a moratorium on Medicaid terminations of coverage because of a federal “continuous coverage” requirement, which remains in effect for the duration of the public health emergency (PHE). The PHE has been extended by the federal government in 90 day increments. As of October 13, 2022, the PHE has been extended to January 11, 2023. 

It is unknown whether the PHE will be extended beyond January. However, the Biden administration has notified governors that it will give states 60 days notice before the PHE expires. This means that by mid-November we should know whether the PHE will be extended through mid-April 2023.

What is the Medicaid continuous coverage requirement?

Since March 2020, as a condition of getting increased federal Medicaid funding during the pandemic, the state must maintain Medicaid coverage for most enrollees regardless of changes in their income or other circumstances. This protection will stay in place for the duration of the federal PHE. 

When will the federal public health emergency end?

It is unknown. The PHE is declared through federal executive orders that are renewed in 90 day increments by the Secretary of the U.S. Department of Health and Human Services (HHS). Since March 2020, HHS has extended the PHE multiple times.

Will enrollees get advance notice before their Medicaid coverage ends?

Federal law requires states to provide an enrollee prior notice and an opportunity to appeal before their Medicaid coverage is terminated. Also, before providing this advance notice, the state must assess whether an enrollee is eligible under any Medicaid coverage category and if so, seamlessly transition the enrollee to the other coverage group. The federal government has provided states detailed guidance on proper implementation of these protections. The state is currently developing an implementation plan.  

How many families have kept Medicaid coverage due to the continuous coverage requirement? 

The state has not published the number of families who have been able to keep Medicaid coverage due to the continuous coverage requirement. However, enrollment data published by the Agency for Health Care Administration show that Medicaid enrollment has increased by over 1 million since March 2020. Most of the growth is for coverage of children and parents. This is not surprising given loss of income, jobs, and employer-based insurance during the pandemic.

How many families will eventually lose Medicaid after the continuous coverage requirement expires?

A recent study projects that as many as 1 million Floridians could lose coverage. Health care coverage losses will inevitably be higher in states that have not expanded their Medicaid programs for adults with income up to 138 percent of the poverty level. Currently, Florida's income limit for parents is  30 percent of the poverty level, or  just $6,984 per year for a three-person family. It is expected that thousands of children and parents — particularly low wage workers — will become uninsured after the continuous coverage requirement expires. The number of uninsured people in Florida, 2.7 million, is already one of the nation’s highest.    

What steps can Medicaid beneficiaries take now to protect their coverage?

Once the PHE ends, the Department of Children and Families (DCF) will be mailing notices to let Medicaid beneficiaries know what they need to do to keep their Medicaid, or if no longer eligible, how to transition into other health coverage like the Affordable Care Act Marketplace or KidCare. Without a current mailing address, mail can get lost and beneficiaries risk losing coverage just because DCF is unable to reach them.

Beneficiaries can update their addresses on the ACCESS website or through the DCF call center. However, call center wait times are long, so DCF is encouraging beneficiaries to instead make the changes through the website. If a beneficiary already has an online account, they can update their address through the new chatbot feature (called “DCF's Virtual Assistant”) that pops up on the website. Beneficiaries will need to enter their social security number or their birthdate and DCF case number to update their address.

Beneficiaries without an online account can also create one. The ACCESS website includes "how to" videos.

What steps can policymakers take now to keep people covered by Medicaid after the federal PHE ends?

Expanding Medicaid, either through action taken by the Florida Legislature or Congress, would be the best way to minimize coverage losses. However, there are multiple additional steps the state can take now to reduce the risk that eligible Floridians will lose coverage and decrease administrative burdens for state staff and enrollees. This includes ongoing engagement of enrollees, providers, and community-based organizations to solicit their recommendations, as well as being transparent on proposed plans and letting these stakeholders know what to expect when the continuous coverage requirement ends.

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