Unwinding the Medicaid Continuous Coverage Requirement FAQ

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

In March 2020, as part of COVID-19 relief legislation, 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 prohibits states from terminating most Medicaid enrollees’ coverage until after the public health emergency (PHE) ends, as determined by the U.S. Department of Health and Human Services. During the PHE, Medicaid agencies can’t disenroll anyone from Medicaid unless they ask to be disenrolled, move out of state, or die. Continuous coverage has allowed millions of people to stay covered without any interruption during the pandemic — and it’s a major reason why there hasn’t been an increase in the uninsured rate during the pandemic. The PHE is expected to end in mid-July, in which case the continuous coverage requirement would end July 31, 2022. When the requirement ends, states will begin the process of “unwinding” and reviewing all their enrollees’ eligibility for Medicaid.