HHS extends special enrollment period for former Medicaid beneficiaries

HHS has extended the temporary special enrollment period to facilitate marketplace enrollment for beneficiaries who lost Medicaid or Children’s Health Insurance Program (CHIP) coverage following eligibility renewals.

The Medicaid continuous coverage policy ended on March 31, 2023, and states could resume eligibility determinations on April 1, 2023.

CMS announced the special enrollment period on January 27, 2023, allowing former Medicaid or CHIP beneficiaries in marketplaces served by HealthCare.gov to enroll in health insurance coverage outside the annual open enrollment period.

CMS’ initial announcement stated that marketplace-eligible consumers who submit applications between March 31, 2023, and July 31, 2024, and attest to a last date of Medicaid or CHIP coverage during the same period are eligible for the special enrollment period. Consumers initially had 60 days after their submission to select a marketplace plan, with coverage starting on the first day of the month after they choose a plan.

Most states anticipated completing their coverage redeterminations by mid-2024. However, procedural disenrollment pauses, the adoption of strategies to promote continuous coverage, and other state-specific issues have caused many to extend their unwinding timelines.

Given these updates, HHS has extended the special enrollment period’s end date to November 30, 2024. In addition, individuals will now have 90 days or longer instead of 60 days after coverage loss to select a marketplace plan.

This extension will facilitate marketplace enrollment for those losing Medicaid or CHIP coverage through the start of the next open enrollment period. State-based marketplaces are not required to implement a special enrollment period but can implement similar measures.

“The actions we are announcing today, like those we have taken over the past year, demonstrate that HHS is committed to ensuring Medicaid and CHIP coverage for all who are eligible. We are helping those who will now qualify for Marketplace coverage obtain it,” HHS Secretary Xavier Becerra said in the press release.

“We encourage states to use all the strategies and resources we have provided them to carry out renewals of coverage. We will continue to monitor the renewal process and make sure federal requirements are being followed.”

Additionally, CMS has released guidance on the unwinding process, highlighting important federal renewal requirements states must follow. The agency also provided resources states can reference when completing renewals.

CMS has released guidance for Medicaid managed care plans on how they can maximize coverage continuity and resources for state partners on how to help families navigate Medicaid fair-hearing processes.

As of March 2024, more than 18 million beneficiaries have been disenrolled from Medicaid, exceeding HHS’ initial projection of 15 million. Texas has disenrolled the most beneficiaries so far at 2 million, while Wyoming has disenrolled the fewest at 5,300. Most disenrollments have occurred due to beneficiaries not completing the required renewal process to maintain coverage, referred to as procedural reasons.