Section 1115 Waiver Watch: Continuous Eligibility Waivers and Implications for Unwinding


Beginning April 1, 2023, states can resume Medicaid disenrollments for the primary time in 3 years. The Households First Coronavirus Reaction Act (FFCRA) enacted at first of the COVID-19 pandemic incorporated a demand that state Medicaid techniques stay folks continuously enrolled in change for enhanced federal matching price range. The Consolidated Appropriations Act (CAA) handed in December 2022 set an finish date of March 31, 2023 for the continual enrollment provision. KFF estimates that this provision has contributed to a 33% build up in Medicaid enrollment. An estimated 5 to 14 million people may lose Medicaid protection throughout the unwinding of the supply.

How states manage the unwinding process may have an effect on what number of people are ready to deal with protection or transition to different protection if they’re not eligible. Whilst all enrollees will wish to go through a renewal procedure throughout the unwinding, states can advertise continuity of protection after renewal by way of offering steady eligibility to positive populations. This Waiver Watch summarizes authorized and pending Section 1115 demonstration waivers in seven states with steady eligibility provisions that might lend a hand decrease protection loss.

Below present regulation, states give you the option to increase 12-month steady eligibility for youngsters and for postpartum protection. Below a continual protection coverage, people who are made up our minds to be eligible can deal with Medicaid protection for a particular time period, irrespective of fluctuations in revenue, sooner than a redetermination duration to decide ongoing eligibility. Those insurance policies had been shown to lower churn, which happens when folks quickly lose Medicaid protection and disenroll after which re-enroll inside of a brief time period. As of January 2023, 33 states have followed the choice this is to be had beneath present regulation to offer 12-month steady eligibility for some or all youngsters in Medicaid and/or CHIP. Below the CAA, beginning in 2024, all states shall be required to offer 12-month steady eligibility for youngsters. The American Rescue Act Plan (ARPA) allowed states a short lived possibility to offer 12-month postpartum protection, and the CAA made this selection everlasting. States can not supply steady protection to youngsters or postpartum folks for longer than three hundred and sixty five days—or to different adults in any respect—with no waiver.

Six states (KS, MA, NJ, NY, OR and WA) have authorized waivers and one state (NM) has a pending request to increase steady eligibility past what is authorized beneath federal regulation (Desk 1). Segment 1115 waivers permit states to acquire federal approval to function their Medicaid techniques in ways in which fluctuate from what is needed by way of federal statute. Just lately, seven states have sought such waivers to offer steady eligibility this is extra beneficiant than in a different way allowed, for youngsters (3 states) and/or adults (5 states). Those waivers additionally range by way of:

  • Length of protection: KS, MA, NY and NJ have gained acclaim for 12-month steady eligibility for all or some adults (and MA may even supply 24-month steady eligibility to positive adults). OR is the primary state to obtain authorization to offer two years of continuing eligibility for all enrollees age six and over. OR and WA even have approval to offer steady protection for babies via age six, and NM has asked a identical provision.
  • Goal inhabitants: Along with concentrated on youngsters and/or adults, states would possibly position different limits at the populations eligible for steady protection insurance policies. The vast majority of states (NY, NJ and OR) have gained or are looking for approval to offer steady eligibility to all income-eligible enrollees. On the other hand, KS will prohibit 12-month steady eligibility to folks and caretaker kin. MA will supply 12-month steady eligibility for people following liberate from a correctional establishment and 24-month steady eligibility for people experiencing homelessness.

Having a look forward, steady eligibility insurance policies will stay the most important lever for stabilizing Medicaid protection, following the unwinding of the continual enrollment provision. As famous above, the CAA mandates all states to put into effect 12-month steady eligibility for youngsters in Medicaid and CHIP, beginning in 2024. Mandatory continuous enrollment can lend a hand youngsters deal with protection. KFF research means that Hispanic youngsters could also be much more likely to enjoy revenue volatility or lose protection at renewal for procedural causes than youngsters of alternative races, so those insurance policies may additionally scale back racial disparities and advertise well being fairness. Because the COVID-19 steady enrollment provision unwinds, new steady eligibility insurance policies that some states are pursuing via 1115 waivers can give solid protection past the bounds allowed or required beneath present laws. Such insurance policies are anticipated to extend Medicaid enrollment and due to this fact prices total, however also are prone to decrease churn, scale back administrative prices, give a boost to well being results and probably lower in step with enrollee prices because of much less fragmented care.


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