Managed Care Outlook 2023

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Read time: 7 minutes

January 31, 2023, will mark three years since the day the U.S. Department of Health and Human Services (HHS) first declared a public health emergency (PHE) due to COVID-19. The federal government passed a cascade of new laws, regulations, and guidance that affected many different aspects of American life, from rent and student loan payment moratoriums to increased family food benefits to expanded access to health care, COVID-19 testing and related items and services, and telehealth. While a few of these benefits will continue, most will expire once the PHE ends. The PHE will end on May 11, 2023, and managed care companies should be prepared for the fallout.

Autores: Jason T. Mayer

Here, we provide a brief overview of the state of the PHE, followed by a discussion of expected changes in Medicaid enrollment, COVID-19 testing and related items and services and telehealth services.

The state of the PHE

HHS first declared a PHE due to COVID-19 on January 31, 2020, and it has renewed the PHE every 90 days throughout the Trump and Biden administrations to date. On January 30, 2023, the Biden administration informed Congress that it will end the PHE on May 11.

Expected drop in Medicaid enrollment

The Families First Coronavirus Response Act (FFCRA), one of two signature pieces of federal COVID-19 legislation, increased funding to states for Medicaid so long as the state met certain requirements. One of those requirements is that the state maintain enrollment for those who were eligible for Medicaid as of January 1, 2020, for the duration of the PHE. Ordinarily, individuals must renew their Medicaid coverage annually and show that they meet income and other eligibility requirements. However, under the FFCRA, states receiving extra federal funds through the FFCRA cannot disenroll Medicaid recipients during the PHE so long as the recipient was eligible as of January 1, 2020, is still a state resident, and has not voluntarily left the program. HHS estimates that this “continuous enrollment condition” led Medicaid enrollments to increase by more than 19 million individuals, or nearly 29 percent, during the pandemic.

Through its most recent spending package, Congress has accelerated the end of these provisions. Under the legislation, states may begin processing Medicaid redeterminations of eligibility as soon as April 1. In addition, the enhanced federal funding called for by the FFCRA will phase down between April and the end of 2023. As a consequence of these changes, HHS estimates that up to 15 million people will be disenrolled in the Medicaid program, including nearly 7 million who remain eligible but nevertheless will be disenrolled due to bureaucratic hurdles.

While Medicaid managed care organizations (MCOs) should prepare for a decline in enrollment, MCOs can assist state Medicaid agencies in communicating to enrollees about the end of the continuous enrollment condition to improve coverage and member retention. Outreach and assistance to both state agencies and members is essential to minimizing disenrollment for eligible members.

Key takeaways
  • The end to the COVID-19 public health emergency on May 11, 2023, and recent federal legislation will also end temporary changes that increased Medicaid enrollment, set coverage and pricing requirements for COVID-19 diagnostic testing, and expanded telehealth access.
  • Medicaid MCOs should plan outreach and assistance to both state agencies and members to minimize expected disenrollment for eligible members.
  • All plans should prepare for how they intend to cover COVID-19 testing and telehealth and other remote services once the PHE ends.
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