Anne Swerlick
July 16, 2021

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

This post was last updated on September 29, 2021. As new policies are announced, FPI will update this page.

As Florida’s response to COVID-19 takes front and center, concern grows for low-income families who struggle to take precautions against the spread of the virus. Although Congress has passed the Families First Coronavirus Response Act to address, at least in part,  the public health crisis and economic fallout from COVID-19, many barriers continue to keep struggling families from accessing the assistance they need during the pandemic. As Florida initiates policies implementing the Act and addressing other barriers to the safety net, FPI will update this form. When available, hyperlinks are provided to agency documents or statements that provide greater detail  about the new policy.

On March 22, 2020, FPI and 44 other organizations sent a letter to Governor DeSantis, leadership in the Legislature and agency heads to urge action on 47 specific policy changes to reduce unnecessary barriers for Florida’s safety net programs in response to the COVID-19 pandemic. See the letter here.

On June 26, 2021 Florida’s COVID-19 public health emergency (PHE) declaration expired. However, the federal government has also declared a PHE, and that declaration is ongoing. This means that Medicaid enrollees (enrollees) in Florida remain protected by the "continuous coverage" requirement.

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?

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). The federal PHE is projected to continue at least through the end of 2021. When a decision is made to terminate the federal PHE, HHS will give states 60 days' prior notice.

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. During December 2020, the federal government provided states some guidance on implementation of these protections. However, additional federal instructions to states are expected to help ensure that eligible Medicaid enrollees maintain their coverage after the PHE ends.

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 (AHCA) 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?

At this point, it is unknown. However, coverage losses will inevitably be higher in states that have not expanded their Medicaid programs for adults up to 138 percent of the poverty level. Currently, Florida's income limit for parents is 31 percent of the poverty level, or $6,936 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 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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