What the End of the Public Health Emergency Means for People with Low Incomes

By Suzanne Wikle and Teon Dolby 

Since January 2020, a federal Public Health Emergency (PHE) has been in effect due to the ongoing COVID-19 pandemic that has cost nearly a million lives in America and disrupted practically every aspect of our communities. By March 2020, schools were closed, parents were unable to work without child care or schools open, and workplaces were temporarily or permanently shut down, causing the largest job losses in history. Congress swiftly responded with enhanced unemployment benefits, stimulus payments directly to people, and improvements to existing benefit programs.  While some provisions have already ended, many enhancements to public benefit programs are still in place because of the PHE and will go away when the PHE ends. 

The U.S. Department of Health and Human Services (HHS) has renewed the PHE every 90 days. It was last renewed on April 14, 2022, but future renewals are uncertain at this time. When the PHE does expire it’s more than a formality. Its end will halt pandemic-era provisions that have strengthened our system of basic needs programs. Now is the time to make plans to ensure that this ending does not leave people with low incomes stranded.  Changes to the safety net after the PHE ends include: 

  • The Medicaid continuous coverage provision will end. Since March 18, 2020, people insured by Medicaid have benefitted from continuous enrollment and no gaps in health insurance coverage. The continuous coverage provision will expire on the last day of the month in which the PHE ends, and states will have to redetermine eligibility for everyone who is receiving Medicaid. As a result, many people will be at risk of losing Medicaid coverage—including those who remain eligible—due to paperwork and bureaucratic challenges. However, large coverage losses are preventable. The Centers for Medicare & Medicaid Services (CMS) has given states several options to help retain as many people as possible, including allowing states to take up to 12 months to review all cases, receiving updated enrollee addresses from Medicaid Managed Care Organizations (MCOs), and using SNAP enrollment to renew Medicaid. States should be planning now for the end of the continuous coverage provision and actively engaging stakeholders in order to make the process as smooth as possible. See these resources for an in-depth explanation of the continuous coverage provision, steps advocates can take to minimize coverage loss, and guidance and resources from CMS.  
  • Emergency Allotments (EAs) that increased benefits for SNAP recipients will end in all states. The Families First Coronavirus Response Act allowed states to provide emergency SNAP benefits to all households enrolled in SNAP up to the maximum monthly benefit amount. Starting in April 2021, the Biden Administration allowed households with the lowest incomesthose already receiving the maximum benefitto receive an additional $95 a month. When the PHE ends, SNAP households in states providing emergency allotments will on average experience a cut in their benefits of about $80 per person per month, approximately a 33 percent decrease in monthly benefits. When the national PHE ends, all states still providing emergency allotments will have one additional month to start transitioning all participants off EAs. Forty states have acknowledged extensions through April 2022.  
  • The three-month time limit on food assistance for unemployed or underemployed individuals will resume. Due to a 1996 law, certain adults ages 18-49 without dependents are subject to a 3-month time limit of SNAP benefits over 3 years unless they work or participate in a work program for at least 20 hours a week. In March 2020, Congress prohibited states from cutting people off SNAP due to the program’s time limits unless they refused an employment and training opportunity offered through SNAP. The time limit suspensions will end one month after the PHE is lifted. However, states are able to request waivers of the time limit based on unemployment rates.  States should also exempt people who are experiencing long COVID or who are at high risk of COVID complications from the time limits. 
  • The temporary SNAP expansion for college students will end. Under SNAP standard eligibility, students attending college more than part time are not eligible to receive benefits unless they meet an exemption, such as having young children or working 20 hours or more per week. However, the Consolidated Appropriations Act, 2021 temporarily expanded SNAP benefits to otherwise eligible students who either participate in the work-study program or have an expected family contribution of $0. The temporary exemptions will be in effect until 30 days after the conclusion of the PHE. Students who currently have benefits will keep them until their recertification period. Many of these students will qualify for SNAP based on another exemption, and states should check to see if they do so before ending their benefits. 

 The PHE has played a key role connecting people to health insurance and increasing nutrition assistance during a time of great need. Although the PHE may end in the coming months, people’s need for affordable health care and nutrition assistance certainly won’t end. The pandemic provisions show that our country can use policy change to improve the lives of those who are struggling to make ends meet, put food on the table, and afford health care. Moving forward, prioritizing changes like what we’ve seen during the pandemic—such as at least 12 months of continuous coverage in Medicaid, eliminating work requirements for food assistance, and increasing SNAP allotments—stand to improve the effectiveness of our safety net and improve our neighbors’ lives.