Medicaid: What to Watch in 2022 – Kaiser Family Foundation – DC Initiative on Racial Equity
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As 2022 kicks off, a number of issues are at play that could affect coverage and financing under Medicaid, the primary program providing comprehensive health and long-term care coverage to low-income Americans.  New COVID variants are surging and the fate of the Build Back Better Act (BBBA), a reconciliation bill that includes significant changes to health coverage and Medicaid, is hanging in the balance.  In addition, Governors are poised to release proposed budgets amid continued uncertainty about the health and economic trajectory of the pandemic while the Biden Administration continues to use its authority to address the pandemic and to further strategic goals to expand coverage and access and to improve equity.  Within this context, this issue brief examines key issues to watch in Medicaid in 2022.

Medicaid Coverage and Enrollment

Enrollment and the pandemic.  Since the start of the coronavirus pandemic, enrollment in Medicaid and the Children’s Health Insurance Program (CHIP) grew to 83.2 million in June 2021, an increase of 12.0 million (16.8%) from February 2020. Enrollment growth reflects downturns in the economy due to the pandemic and provisions in the Families First Coronavirus Response Act (FFCRA) that require states to ensure continuous coverage for current Medicaid enrollees to access a temporary increase in the Medicaid match rate during the Public Health Emergency (PHE) period, recently extended to April .  Continuous enrollment has helped to preserve coverage and halted Medicaid churn, however, when these requirements end, states will begin processing redeterminations and renewals and millions of people could lose coverage if they are no longer eligible or face administrative barriers during the process despite remaining eligible. The Centers for Medicare and Medicaid Services (CMS) has released guidance and strategies for states to help maintain coverage of eligible individuals after the end of continuous enrollment requirements.  The BBBA also includes provisions that would phase-out the continuous enrollment requirement beginning April 1, 2022 with rules about disenrolling people tied to a phased down enhanced match rate.  Within the parameters set by the Administration, or BBBA if enacted, states will largely be responsible for managing the unwinding of the continuous enrollment requirement, which could lead to variation in practices and in how many people are able to maintain coverage.

State decisions around Medicaid coverage.  Beyond the pandemic and continuous enrollment requirements, the American Rescue Plan Act (ARPA) included new coverage options for states.  ARPA provides a two-year fiscal incentive to encourage states to newly adopt the Medicaid expansion.  Over  2 million individuals living in the 12 states that have not adopted the Affordable Care Act’s (ACA) Medicaid expansion fall into the coverage gap because they do not qualify for Medicaid and have incomes below poverty, making them ineligible for premium subsidies in the ACA Marketplace. A KFF analysis shows that all non-expansion states would see a net fiscal benefit from the ARPA incentive for two years if they adopt the expansion.  The ARPA federal incentive reignited discussion around Medicaid expansion in a few non-expansion states during the last state legislative session, but no state newly voted to adopt the expansion. South Dakota will have a Medicaid expansion constitutional amendment on the November 2022 ballot.  Six states have adopted the expansion by ballot initiative (Idaho, Maine, Missouri, Nebr


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