Medicaid enrollment has risen to unprecedented levels since the start of the COVID-19 pandemic. The most recent data at the time of this writing show enrollment jumped by nearly 13 million people from February 2020 to July 2021. In an earlier analysis, we showed that most of this new Medicaid enrollment was from the continuous coverage requirement of the Families First Coronavirus Response Act, which prohibits state Medicaid agencies from disenrolling beneficiaries during the public health emergency (PHE). Determining what will happen to the health coverage of these millions of new enrollees and how to avoid a large increase in the number of people uninsured after the PHE ends are urgent issues for policymakers this year. Many of the people who disenroll from Medicaid at the end of the PHE are estimated to be eligible for Marketplace subsidies, but not all of them will enroll. The enhanced premium tax credits (PTCs) enacted by the American Rescue Plan and currently in place through 2022 increase the likelihood of take-up of Marketplace coverage by those leaving Medicaid. Under current law, however, these enhanced PTCs will expire unless Congress acts this year to extend them into or beyond 2023. Fewer people leaving Medicaid will enroll in Marketplace coverage if the enhanced PTCs expire. The legislation that enacted the continuous coverage requirement also increased the share of Medicaid costs paid for by the federal government, rather than the state. This enhanced federal medical assistance percentage (FMAP) will expire in the quarter following the end of the PHE, creating financial pressure for states to redetermine eligibility for current enrollees soon after the PHE ends. Current guidance from the US Department of Health and Human Services (HHS) gives states up to 14 months after the PHE to return to normal eligibility processing to spread the administrative burden of processing redeterminations for large numbers of enrollees over time, but states may choose to process them more quickly. On January 14, 2022, the HHS secretary extended the PHE for 90 more days. The PHE will likely be extended through the second quarter of 2022, though this has not been officially confirmed at the time of this writing. The future of the pandemic is still uncertain, so even further extension is possible. In this brief, we update our earlier estimates of Medicaid enrollment and costs, which assumed the PHE would not be extended into 2022, consistent with HHS guidance at the time.4 We also improve the accuracy of our projections, particularly at the state level, by incorporating the latest Medicaid enrollment data.
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