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Get to Know the Public Health Emergency and Medicaid

 
Federal and state agencies are beginning to prepare for the end of the federal Public Health Emergency (PHE). Read on to learn more about what the end of the PHE means for Medicaid patients.
 
What is the Public Health Emergency? 
Under the Public Service Act, the U.S. Department of Health and Human Services (HHS) has the authority to declare a Public Health Emergency (PHE) in the face of an infectious disease, disorder, or event such as a bioterrorist attack. Federal public health emergencies last for 90 days and must be reauthorized by HHS.1  
 
What does the Public Health Emergency allow HHS to do? 
A federal Public Health Emergency declaration allows HHS to take several actions, including the following: 
  • Make grants  
  • Investigate the public health threat 
  • Access different funding sources to quickly respond to the emergency 
  • Modify the practice of telemedicine 
  • Waive or modify certain Medicare, Medicaid, or Children's Health Insurance (CHIP) and Health Insurance Portability and Accountability (HIPAA) Privacy Rule Requirements2 
 
What is the status of the COVID-19 Public Health Emergency? 
The federal government first declared a Public Health Emergency (PHE) in January of 2020 in response to the COVID-19 pandemic. The PHE has been extended in 90-day increments since that time, most recently through July 15, 2022. The Biden administration has stated it will notify states that the PHE will not be extended at least 60 days in advance. Since the Biden administration did not notify states the PHE would be ending on July 15, the PHE is expected to be extended for at least another 90 days to October 13, 2022.3 
 
How is Medicaid financed? 
Medicaid is a joint state-federal program. The federal government matches each state's spending on their Medicaid program based on a funding formula known as the Federal Medical Assistance Percentage (FMAP). Since the FMAP incorporates each state's per capita income, the FMAP varies from one state to another. Tennessee's FMAP percentage for FY23 is 66.1%, which means the federal government pays for about 2/3 of the costs of Tennessee's Medicaid program.4 
 
How has the pandemic affected Medicaid enrollment? 
When Congress passed the Families First Coronavirus Response Act (FFCRA), the legislation authorized an enhanced FMAP for states if they met maintenance of eligibility requirements. States received an additional 6.2% added to their FMAP if they didn't disenroll anyone from their state's Medicaid program during the Public Health Emergency. Tennessee's FMAP rose to approximately 72% during the pandemic.5 Due to the continuous coverage provision, national Medicaid enrollment rose to 85 million people, a 19% increase.6 In Tennessee, 300,000 additional enrollees were added to TennCare, the state's Medicaid program.7  
 
What does the end of the PHE mean for Medicaid enrollment? 
The continuous coverage requirement will end at the end of the month in which the PHE ends and the enhanced FMAP will apply through the end of the quarter in which the PHE ends.8 After the PHE ends, states will have to resume the eligibility determinations. The Centers for Medicare and Medicaid Services (CMS) released guidance that gives states up to a year after the end of the PHE to begin the redetermination process and 14 months to complete it.9 

There are concerns enrollees will lose coverage once the redetermination process begins. Enrollees may no longer meet the eligibility criteria or may lose coverage because they do not complete the necessary renewal paperwork. States are working to inform members of the upcoming renewal process, make the process as simple as possible, and help folks transition to other forms of coverage if they are no longer eligible for Medicaid.10  

TennCare is preparing for the end of the PHE and encouraging TennCare members to update their address, phone numbers, and number of people in their household so TennCare can have up-to-date information when the renewal process begins. Members can update their information using TennCare Connect's online portal, or by calling TennCare at 855.259.0701. 
 
 
 
[1] Public Health Emergency Declaration. (2022). Retrieved from https://www.phe.gov/Preparedness/legal/Pages/phedeclaration.aspx 
[2] Ibid. 
[3] Wagner, J., & Erzouki, F. (2022). Time to Get It Right: State Actions Now Can Preserve Medicaid Coverage When Public Health Emergency Ends. Retrieved from https://www.cbpp.org/research/health/time-to-get-it-right-state-actions-now-can-preserve-medicaid-coverage-when-public 
[4] Federal Medical Assistance Percentage (FMAP) for Medicaid and Multiplier. (2022). Retrieved from https://www.kff.org/medicaid/state-indicator/federal-matching-rate-and-multiplier/?currentTimeframe=2&sortModel=%7B%22colId%22:%22FMAP%20Percentage%22,%22sort%22:%22desc%22%7D 
[5] Ibid. 
[6] States Are Planning for the End of the Continuous Enrollment Requirement in Medicaid After the COVID-19 Public Health Emergency Expires, But Many Have Not Made Key Decisions. (2022). Retrieved 1 June 2022, from https://www.kff.org/medicaid/press-release/states-are-planning-for-the-end-of-the-continuous-enrollment-requirement-in-medicaid-after-the-covid-19-public-health-emergency-expires-but-many-have-not-made-key-decisions/ 
[7] Farmer, B. (2022). TennCare expects 300,000 to lose coverage after pandemic ends. Retrieved from https://wpln.org/post/tenncare-expects-300000-to-lose-coverage-after-pandemic-ends/ 
[8] Fiscal and Enrollment Implications of Medicaid Continuous Coverage Requirement During and After the PHE Ends. (2022). Retrieved from https://www.kff.org/medicaid/issue-brief/fiscal-and-enrollment-implications-of-medicaid-continuous-coverage-requirement-during-and-after-the-phe-ends/#:~:text=The%20MOE%20continuous%20eligibility%20requirement,a%20short%20period%20of%20time
[9] States Are Planning for the End of the Continuous Enrollment Requirement in Medicaid After the COVID-19 Public Health Emergency Expires, But Many Have Not Made Key Decisions. (2022). Retrieved 1 June 2022, from https://www.kff.org/medicaid/press-release/states-are-planning-for-the-end-of-the-continuous-enrollment-requirement-in-medicaid-after-the-covid-19-public-health-emergency-expires-but-many-have-not-made-key-decisions/ 
[10] Wagner, J., & Erzouki, F. (2022). Time to Get It Right: State Actions Now Can Preserve Medicaid Coverage When Public Health Emergency Ends. Retrieved from https://www.cbpp.org/research/health/time-to-get-it-right-state-actions-now-can-preserve-medicaid-coverage-when-public 

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