In March of 2020, under the federal Families First Coronavirus Response Act (FFCRA), all individuals who were enrolled in Ohio Medicaid or became enrolled after March 18, 2020 were not permitted to be disenrolled from the program unless the individual met one of the following circumstances:
- voluntarily requested the discontinuance of Medicaid coverage
- was no longer a resident of Ohio, or
As a result, individuals who were enrolled in Medicaid maintained their coverage and were not required to go through the typical annual process of renewing their eligibility. Then, in late 2022, the U.S. Congress passed the Consolidated Appropriations Act of 2023 (CAA 2023) which separated the Medicaid continuous coverage requirement from the Public Health Emergency (PHE) declaration. While the PHE continues, Medicaid continuous coverage ends in March.
The enhanced funding to support continuous Medicaid coverage from the federal government was about $5.1 billion over 16 quarters.
Overall, the enhanced funding to support continuous Medicaid coverage from the federal government was about $5.1 billion over 16 quarters. It should be noted that none of this funding went to the Medicaid expansion population (given the existing high federal match) and primarily benefitted the older Ohioans and individuals with disabilities, in terms of overall spending. States will continue to receive the 6.2 percentage enhanced federal medical assistance payment (eFMAP) during the first quarter of 2023 after which it phases down before the end of 2023—subject to additional federal requirements.
Over the course of the PHE, Ohio Medicaid is expected to have a total caseload of nearly 3.5 million individuals, which would be an increase of roughly 800,000 people. Within that group, 40 percent of the enrollees were children.
It’s important to note that the state cannot simply disenroll individuals from the program and there are a number of requirements Ohio Medicaid must follow with regard to maintaining contact information, issuing corrective action plans with potential penalties if states fail to appropriately manage disenrollment and, importantly, additional federal match penalties for non-compliance with reporting.
It’s important to note that the state cannot simply disenroll individuals from the program.
The first Medicaid benefits that may be discontinued are benefits scheduled for an April 2023 Medicaid renewal. Cases that are not renewed will be closed effective May 1, 2023. Other individuals may be discontinued as early as April 1, 2023, based on a reported change.
County job and family services (CJFS) offices and the state of Ohio have already started this process for April renewals
- In February, the State of Ohio ran an automated renewal process. For individuals successfully renewed, a letter will be mailed to notify them their Medicaid was re-approved.
- On March 1, renewal packets were sent to Medicaid recipients whose benefits could not be renewed automatically. Responses to these renewal packets were due March 31.
- Customers who do not return their renewal packets may be disenrolled from Medicaid. A letter will be sent mid-April, notifying them that their benefits will expire on April 30.
In each subsequent month, this process will be repeated. To explain, for May, autorenewals ran in March and cases that weren’t automatically renewed received renewal packets on April 1 and they are due back to CJFSs by April 30. If they individuals don’t renew, termination letters will be sent in May and beneficiaries will coverage will expire May 31.
200,000 Ohioans are likely going to lose coverage because of the PHE termination.
According to testimony from Kim Murnieks, Director of the Office of Budget and Management, 200,000 Ohioans are likely going to lose coverage because of the PHE termination. However, according to estimates from the Urban Institute, the estimated coverage loss may be closer to 534,000, including 187,000 children. Looking further into data from the Department of Health and Human Services (HHS), about 15 million people, nationally, will lose Medicaid coverage, 7 million of which will lose coverage because of procedural reasons – not due to income ineligibility. This means that between 93,000 and 249,000 individuals in Ohio may lose coverage because of systemic issues tied to processing eligibility.
WHAT DOES THIS MEAN FOR PATIENTS?
The good news is that caseloads are currently trending downward, with less infections and hospital admissions tied to COVID. Additionally, because of many of the policy measures the DeWine administration enacted, Ohio recorded fewer deaths than most of the United States. However, regardless of the current infection rates, long COVID is impacting 1 in 5 adults who survived an infection, with longer term implications regarding health, likely leading to a significant increase in disability rates, nationally. This is one reason, for example, the Biden administration is considering a limited additional vaccine booster this spring for particular populations that Medicaid disproportionately covers. What’s more, while the likelihood of a global recession has been waning, it is not completely gone. And, unfortunately, increased unemployment may actually help mute inflation, according to the Federal Reserve, meaning caseloads in Medicaid are even more difficult to predict.
Given the complexities of a still evolving public health emergency and global economic uncertainty, disenrollment from Medicaid may come at a very difficult time for many beneficiaries and the provider that serve them. In particular, for community-based health providers like safety net hospitals and Federally Qualified Health Centers, who are also experiencing the loss of additional revenue tied to recovery dollars, continuity of care can not only impact their patients but their financial health as well. This is why it will be important for beneficiaries, advocates and providers to stay engaged and keep a close eye as the landscape changes. Here are some key resources to consider:
- Make sure you are up to date on your contact information and ensure you renew your eligibility. For more information on this, you can check Ohio Medicaid’s renewal landing page, reach out to your local county Job and Family Services office, or call the state’s consumer hotline. You can also reach out to Get Covered Ohio and speak with a Navigator who can discuss your options. Especially if you have a new job or may no longer qualify for Medicaid, people can help you explore your coverage options as you may be able to receive subsidized insurance through a Marketplace plan. Go to https://getcoveredohio.org/ or call (833) 628-4467 to learn more.
- Be on the lookout for scams! Criminals are targeting Medicaid recipients to obtain sensitive, personally identifiable information such as your Social Security Number, bank account numbers, and more. If you receive a call, email, or text about your Medicaid benefits that ask for payment, banking, or credit card information, ignore. These are NOT generated by the State of Ohio or any of its agencies. Please report these calls to the State of Ohio Attorney General’s office at 1-800-282-0515 or https://www.ohioprotects.org.
- It’s important that advocates continue to monitor the caseloads and pay attention to any potential violations of the CAA 2023 reporting requirements. The National Health Law Program has a compendium of resources on the guidance to states and other information to stay current with the latest developments.
- It will be key for providers, particularly safety net providers, to work with patients on maintaining their eligibility. For many providers, they have presumptive eligibility powers, so it will be important to work with patients to ensure continuity of care. For community mental health centers, federally qualified health centers, and others, disability service providers and others, this can also include working with the Managed Care Organizations that provide coverage to these populations as they have temporary expanded powers to assist in maintaining eligibility.