Unwinding the Medicaid Continuous Coverage Requirement FAQ

Updated April 2023

By Suzanne Wikle and Jennifer Wagner from the Center on Budget and Policy Priorities (CBPP)

In March 2020, as part of COVID-19 relief enacted in the Families First Coronavirus Response Act (FFCRA), Congress provided increased Medicaid funding to states. States had to meet several conditions to receive the federal funds, collectively called a Maintenance of Effort (MOE) requirement, as well as a “continuous coverage” requirement that prohibited states from terminating most Medicaid enrollees’ coverage until after the end of the public health emergency (PHE), as determined by the U.S. Department of Health and Human Services.

During the continuous coverage requirement, Medicaid agencies couldn’t disenroll anyone from Medicaid unless they asked to be disenrolled, moved out of state, or died. Continuous coverage allowed millions of people to stay covered without any interruption during the pandemic — and it’s a major reason why there wasn’t an increase in the uninsured rate during the height of the pandemic.

In December 2022, Congress passed an omnibus spending bill that delinked the Medicaid continuous coverage requirement from the PHE and ended the continuous coverage protection on March 31, 2023, allowing states to resume Medicaid coverage terminations effective April 1, 2023.