Considerations for State Medicaid and CHIP Agencies As They Prepare to Unwind COVID-19 Eligibility and Enrollment Flexibilities

This commentary explores how states have been required to make numerous changes to their eligibility and enrollment systems, operations, and policies, in order to comply with the enhanced Federal Medicaid Assistance Percentages. As a condition of receiving enhanced federal funding under the Families First Coronavirus Response Act, states are prohibited from terminating individuals enrolled in Medicaid as of March 18, 2020, or determined eligible on or after that date. These continuous coverage requirements run through the end of the month of the public health emergency, which was recently extended to October 22, 2020, and apply to individuals who may have become ineligible at redetermination or due to a change in circumstances mid-coverage year such as those who have aged out of their eligibility category or experienced an increase in income.