解除新冠肺炎突发公共卫生事件

Unwinding theCOVID-19PublicHealth Emergency:FivekeyconsiderationsforMedicaidMCOs Libby Bunzli,MPHZachary J Fohl,FSA,MAAAChristopher T. Pettit,FSA, MAAADiane Sargent,MBA, MS, PTMaureen Tressel Lewis,MBA In early March2022,the Centers for Medicare and Medicaid Services (CMS)issuedguidanceprovidingdirectionto states as theypreparefor the end oftheCOVID-19Public Health Emergency (PHE)andresumeMedicaideligibility and enrollmentactivities as thecontinuous enrollment provision ends.1 1.Engage your state Medicaid agency This is the third state health official letter that CMS haspublished on this topic and focuses on the timelines andprocesses states must follow to resume normal functions andbe compliant with the rules that were in place before the startof the PHE. At the time of this paper, the PHE is set to end July15, 2022.2It is unknown whether the Secretary of the U.S.Department of Health and Human Services (HHS) will renewthe PHE for another 90 day period, though the Secretary hascommitted to giving states at least 60 days’ notice before thePHE expires.3While state Medicaid agencies are the intendedaudience of these communications, returning to normalMedicaid eligibility and enrollment operations also creates veryreal financial and operational implications for Medicaidmanaged care organizations (MCOs). As of January 2022,Medicaid enrollment has increased by nearly 16 million livessince the start of the COVID-19 pandemic as all states havecomplied with the continuous enrollment condition associatedwith increased federal Medicaid matching funding during thePHE.4It remains unclear whether enrollment will normalize topre-pandemic levels after states have conductedrenewals fortheir full caseloads. When the PHE ends, states are expected to resume normalMedicaid eligibility and enrollment activities and processbacklogs in new applications and renewals that may haveaccumulated during the PHE. While some states continued toconduct renewal activities throughout the PHE, CMS isrequiring states to process a new renewal following the end ofthe PHE prior to disenrolling a member. As such, states willneed to conduct renewals for their entire caseload in the 12-month “unwinding period” following the end of the PHE.5However, CMS has indicated that each state’s approach to thetiming of unwinding and distribution of work is at the discretionof state Medicaid agencies. MCOs will want to gain anunderstanding of their states’ operational plans to prepare forany activities plans will need to have in place and the financialimpacts that they can expect to experience over the course ofthe year. Key questions MCOs will want to ask their stateregulators include: How will the state prioritize renewal activities? CMS instructs states to adopt a “risk-based approach” to theirunwinding plans. States can prioritize the workload bypopulations, for instance by starting with individuals who haveaged out of eligibility categories while holding more stablepopulations until theend. States may alternatively schedulerenewals based on the original redetermination date or developtheir own approaches to prioritization. MCOs will want tounderstand the state’s plans for prioritization and timing sothey have a sense of the potential impact on enrollmentthroughout the 12-month unwinding period. This white paper describes five considerations for MCOs asthey prepare for the unwinding of continuous enrollment andother emergency provisions put in place during the PHE. Asthe post-PHE landscape takes shape, MCOs should beprepared to actively engagewith state Medicaid agencies,enhance member support functions, adapt financial planning,monitor member access to providers, and manage impacts toadministrative functions. While this paper focuses onconsiderations for MCOs, state Medicaid agencies mayalsofind these issues to be salient as they develop operationalplans in anticipation of the end of the PHE. Implement effective communications:Even before theglobal pandemic disrupted lives and caused mass migrationacross county and state lines, maintenance of accurate contactinformation for Medicaid members was challenging. As thePHE ends and states resume verification of Medicaid eligibility,we anticipate that the pandemic will have further disrupted thecommunication channels between state Medicaid agenciesand their members, which will exacerbate the challengesstates face when engaging members in the redeterminationprocess and risk inappropriate coverage disruptions andlapses in care.7 Does the state have any estimate of the timing andvolume of membership that will be disenrolled? If states have continued to process renewals throughout thePHE, they may have the capability to estimate the volume ofterminations they anticipate by rate cell during the unwindingperiod.A recent survey found that 20 states were able togenerate an estimate of anticipated disenrollment, whichaveraged 13%(ranging from8% to over 30%)and was mostlyattributed to changes in income.6 How is