The End of the COVID-19 Public Health Emergency: Data and IT “Table Stakes” for Retaining Coverage Gains

Manatt, Phelps & Phillips, LLP
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Following the expiration of the Public Health Emergency (PHE), states will resume normal eligibility and enrollment activities for all enrollees in Medicaid and the Children’s Health Insurance Program (CHIP). The volume of expected redetermination activity at the end of the PHE is unprecedented. Throughout the pandemic, every state has experienced increased enrollment (totaling 10.5 million new Medicaid/CHIP enrollees, a 14.7 percent increase from 2019),1 while having paused regular eligibility and enrollment operations for the over 70 million people that already had health coverage through Medicaid/CHIP. As a result, many enrollees have not gone through the redetermination process in nearly two years, and some have never had to redetermine their Medicaid eligibility because they enrolled during the pandemic. This issue brief reviews state Medicaid/CHIP agency data and information technology (IT) system “table stakes”—strategies that will have the highest impact for states seeking to ensure that eligible enrollees are able to keep or transition to new affordable health coverage when the PHE continuous coverage requirements end. If adopted, these strategies will also enable states to dramatically improve Medicaid/CHIP enrollment and coverage retention in the longerterm for people eligible for government subsidized health coverage.

Originally prepared for the Robert Wood Johnson Foundation’s State Health and Value Strategies program.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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