Part I – Unwinding Medicaid Continuous Enrollment

May 2022

After a slight decline from 2017 to 2019, Medicaid enrollment rose sharply throughout the pandemic. Historically, Medicaid enrollment tracks with unemployment rates. When rates rise, enrollment increases. However, as the world reopened from the pandemic and unemployment hit 50-year lows, we have not yet seen the expected reduction in Medicaid enrollment. This anomaly has been fueled by a continuous coverage (or “Maintenance of Eligibility”) provision that prohibits states from terminating coverage for most Medicaid enrollees until after the federal Public Health Emergency (PHE) declaration ends. That end could be near.

Source: The Kaiser Family Foundation,

The expiration of the PHE will have significant implications for Medicaid enrollment. As a pharmaceutical manufacturer, here’s what you need to know:

Families First Coronavirus Response Act

In 2020, Congress passed the Families First Coronavirus Response Act (FFCRA) that included a requirement for states to provide continuous coverage (or “Maintenance of Eligibility”) for Medicaid enrollees to access temporary funding increases for Medicaid matches during the PHE. As a result, states have been required to maintain enrollment of nearly all Medicaid enrollees throughout the pandemic.

Current Status of the PHE

In April 2022, the U.S. Department of Health and Human Services extended the PHE for another 90 days to mid-July and committed to provide states with 60 days’ notice prior to expiration. To date, there has been no notice to states regarding the PHE expiration, which suggests it could remain in place for another 90 days into mid-October.

In anticipation of the PHE expiration, CMS recently published several tools and a series of webinars to support partners who will manage the eventual unwinding of the continuous enrollment requirement.

Potential Impact to Medicaid Enrollment

When the PHE expires, Medicaid enrollment is expected to decline. Forecasts for those declines have been estimated to be between 5 – 13% of total enrollment1, however the timing for potential declines to be realized will depend upon several factors including the PHE expiration date and the rate at which states implement reevaluation and enrollment changes.

Look for additional information from Prescription Analytics in the future related to the status of the PHE and its potential impact on pharmaceutical manufacturers.

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