Cutting Medicaid and SNAP Red Tape During the Pandemic

By Suzanne Wikle

One year ago, many facets of life and community came to a grinding halt. Schools closed, states issued stay-at-home orders, and businesses shuttered. Millions of people abruptly lost employment – mostly from jobs that pay low wages, such as in restaurants and the service sector – so laid off workers had little savings. Black people, Hispanic people and young adults were hit the hardest by job losses because they are most likely to work in sectors paying low wages.  

In addition to the stimulus payments, enhanced unemployment benefits, and other new programs created in response to the pandemic, Congress made important changes to existing core benefit programs including Medicaid and the Supplemental Nutrition Assistance Program (SNAP).  But the approach Congress took under these two programs was different – in ways that have proven more important than initially recognized.  

Medicaid Improvements 

Under the Families First Coronavirus Response Act (FFCRA) passed in March 2020, states were given additional federal dollars for Medicaid. But in exchange, they had to commit to not cutting people off Medicaid (with few exceptions for voluntary disenrollment, a move out of state, and death) for the duration of the Covid-19  public health emergency. March 18 marked the one-year anniversary of this provision, known as the Medicaid maintenance of effort (MOE) requirement. States were also provided several administrative flexibilities, such as increasing the use of presumptive eligibility and self-attestation. 

The MOE has been monumental for Medicaid because it’s the first time in the program’s history that all recipients have been able to stay enrolled for a full year and counting. Members of Congress included the MOE because they didn’t want states to get additional federal dollars and then restrict access to Medicaid. As a result of the MOE provision—combined with increased demand for Medicaid from those who have lost other sources of insurance—Medicaid enrollment has increased. As of last September, a record 77 million people were insured through Medicaid, and that number is likely higher now. Between February and September 2020 every state saw an increase in Medicaid enrollment. However, only 17 states are reporting an increase in applications, and it appears applications are below pre-pandemic levels. Advocates are speculating that the application data is revealing a truth we’ve always suspected – that “churn” has been a large reason for applications prior to the MOE. 

SNAP Improvements 

FFCRA also approved “emergency allotments” under SNAP to allow all recipients to receive the maximum allotment and gave the Food and Nutrition Service (FNS) authority to grant new waivers to states to respond to the pandemic. However, by late summer, FNS started to deny additional waivers until Congress passed additional legislation that allows states to continue certain flexibilities without requiring FNS approval. For example, states can extend certification periods for SNAP cases by up to six months or waive interviews. A few states never took up the flexibilities at all, and others have returned to business as usual. 

The result has been a very different story about SNAP enrollment. Although the program overall has seen an increase in enrollment since the beginning of the pandemic, there’s been great variance among states. In fact, some states have seen a decrease in SNAP enrollment over the past year. This is true even though surveys find that hunger is at unprecedented levels, particularly among Black and Latino households.  

Going Forward 

These differences give us an important lesson – we should look for ways to eliminate bureaucratic burden, not just make them marginally less difficult.  

The Medicaid MOE means that enrollees don’t have to navigate the paperwork and red tape that comes with renewing their coverage. Not only does this save people time in completing a renewal, but it also eliminates stress related to whether or not their coverage will continue and  the possibility of someone erroneously being disenrolled from Medicaid. Beyond the access to health care, the stability and stress reduction the MOE brings to peoples’ lives is an important part of the conversation. The alleviation of this red tape and associated stress for SNAP varies significantly across states right now, and as a result so do the enrollment numbers.  

While the health crisis was growing, Medicaid was a core part of the country’s response. The response wasn’t perfect, and too many people are still left out – including those in the coverage gap and many immigrants. But policymakers stepped up with the most robust Medicaid response to an economic and health crisis in history. While SNAP also responded, it didn’t cut out as much red tape as Medicaid did, and that seems to be what matters most at the end of the day.