CMS Announces ACA Special Enrollment Period during PHE Unwinding

CMS announced that there will be a special enrollment period on the Affordable Care Act marketplace for individuals who lose their Medicaid coverage due to the public health emergency unwinding.

“Today, CMS is announcing a Marketplace Special Enrollment Period (SEP) for qualified individuals and their families who lose Medicaid or CHIP coverage due to the end of the continuous enrollment condition, also known as ‘unwinding,’” the FAQ sheet explained.

The special enrollment period will stretch from March 31, 2023 to July 31, 2024. In order to be eligible for the special enrollment period, individuals must be eligible for Affordable Care Act marketplace coverage and must have lost their Medicaid, Children’s Health Insurance Program (CHIP), or Basic Health Program (BHP) coverage.

Once consumers apply for Affordable Care Act marketplace coverage, they have a 60-day window to pick a plan. They can enroll before their Medicaid or CHIP healthcare coverage ends. After they select a plan, their coverage will begin the first day of the next month.

For state-based marketplaces, offering the unwinding SEP is not required but is possible.

CMS promised to communicate with stakeholders, offer technical support to enrollment assisters, share information with the press, boost consumer outreach, and offer consumers educational materials through Healthcare.gov.

“Many states and other stakeholders have raised significant concerns that, due to the unprecedented nature of unwinding, Medicaid and CHIP beneficiaries may face exceptional challenges when transitioning from Medicaid or CHIP coverage to other forms of coverage, such as Marketplace coverage,” the FAQ stated.

Enrollees might not understand why their coverage is ending when they have experienced continuous enrollment for so long and they might not have experienced strong communication from their Medicaid agencies.

CMS also expressed concerns that state agencies were not prepared to communicate with enrollees about their options since so many individuals could lose their Medicaid coverage at the same time.

Before the CMS announcement, HHS experts projected that around 15 million beneficiaries would lose their Medicaid coverage due to the unwinding.

As many as 65 percent of beneficiaries may have become uninsured after disenrolling from Medicaid or CHIP, a Kaiser Family Foundation issue brief discovered. Of these, 17 percent remained uninsured for the year. A third were re-enrolled in a public payer program by the end of the year.

Beneficiary communication is crucial to sorting out confusion around enrollment, but Medicaid programs face various challenges in trying to connect and engage with their members. The timeliness and amount of communication, the variety of channels used to share information, and the way that the messaging and delivery conveyed the information’s importance all have the capacity to impact beneficiary communication.