For this study, we spoke with national maternal health leaders and stakeholders in four states in the spring of 2021 to understand how states assessed eligibility for other Medicaid pathways when pregnancy-related Medicaid coverage ended before the COVID-19 public health emergency (PHE), how the continuous enrollment requirement during the PHE changed postpartum coverage, and what steps could increase coverage continuity during the postpartum period following the end of the PHE, including in states that have proposed one-year postpartum Medicaid/Children’s Health Insurance Program (CHIP) extensions.
Many key informants reported that before the PHE’s continuous enrollment requirement, Medicaid eligibility systems did not always facilitate coverage transitions that allowed postpartum people to remain insured. They therefore suggested the following steps the federal government could take to minimize postpartum coverage gaps when normal eligibility processes, including redetermination procedures, resume after the PHE ends:
- First, the Centers for Medicare & Medicaid Services (CMS) could consider extending the redetermination catch-up period from 6 months to 12 months after the PHE expires to avoid overwhelming state systems and help stagger renewals to avoid a glut of redeterminations at the same time in subsequent years. They also suggested CMS provide updated guidance to states on how to handle eligibility transitions after the PHE ends and clarify changes in rules or interpretations under the new administration. On August 13, 2021, CMS issued updated guidance extending the catch-up period to 12 months and prohibiting states from terminating Medicaid coverage until beneficiaries have completed an eligibility redetermination after the PHE ends.
- The federal government could also provide support to navigators, enrollment assisters, community health workers, and others who help people facing redetermination processes navigate systems, understand their coverage options, enroll in coverage, and access needed care.
Key informants also suggested state governments and Medicaid/CHIP agencies could take the following steps:
- effectively communicating expiration of the continuous enrollment requirement and supporting coverage transitions among postpartum enrollees losing Medicaid coverage when the PHE ends, as well as people who will lose coverage after 60 days postpartum after the PHE ends
- proactively updating enrollees' contact information before Medicaid eligibility ends, so they can be reached to provide information needed at redetermination
- facilitating transitions to Marketplace coverage for those losing Medicaid eligibility but eligible for premium subsidies
- supporting access to and use of postpartum health care for those with coverage by reducing barriers to seeking care related to child care, transportation, low health literacy, and work
In addition, key informants highlighted the role of social service and community-based organizations, health care providers, and managed-care organizations in assisting clients during coverage transitions and surfaced strategies for minimizing postpartum coverage gaps in states adopting postpartum Medicaid/CHIP extensions.