States cannot terminate current Medicaid beneficiaries during the COVID-19 Public Health Emergency, which was set to expire on July 16, 2022.   However, DMAS has previously agreed that the states will have at least 60 days’ notice of the termination of the Public Health Emergency, since the tsunami of re-evaluations and re-certifications and/or terminations is going to overwhelm the state Medicaid agencies in spite of their intensive preparations.

The Georgetown University Health Policy Institute noted recently:  “The Biden administration did not provide states with a 60-day notice earlier this week, so we know it will be extended beyond its current end date of July 15, 2022 — most likely another 90-day determination to October 13, 2022. . .  With the new extension now assured (assuming it is a 90-day extension), the first date for possible Medicaid disenrollments would be November 1st, 2022.  

And enhanced federal funding for Medicaid and CHIP (6.2% increase in federal Medicaid share/4.34% for CHIP) will continue through the end of calendar 2022.” 

While we wait to see what the extension might be, the good news for our clients is that they have some breathing room to bring their finances into compliance with the Medicaid financial eligibility requirements before the Public Health Emergency ends and file reviews begin.   States are not permitted to disqualify beneficiaries retroactively, so any beneficiary who is in compliance as of the end date of the Public Health Emergency should have their benefits continued without interruption or penalty.