Strategies to Ensure Continuous Coverage for Children at the End of the Public Health Emergency

Manatt, Phelps & Phillips, LLP

The Families First Coronavirus Response Act (FFCRA) provides enhanced federal matching funds to states as a condition of maintaining Medicaid enrollment until the conclusion of the COVID-19 public health emergency (PHE).1 As a result of the federal “continuous coverage” requirement, children’s enrollment in Medicaid and the Children’s Health Insurance Program (CHIP) has increased by 15.5 percent since February 2020, providing health insurance coverage for nearly 40.5 million children. When the PHE concludes, states will need to redetermine eligibility for all Medicaid enrollees, which may result in unintended coverage loss among children eligible for Medicaid or CHIP. One study estimates that 6.7 million children could lose Medicaid coverage at the end of the PHE.

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