Continuous Enrollment Provision and the Unwinding of the Provision

The continuous enrollment provision prohibited terminating an individual’s Medicaid coverage. Under the provision, the process for Medicaid’s regular eligibility renewal and redetermination was under postponement, creating conditions for states to participate in continuous enrollment of the Medicaid coverage program.17 Essentially, the continuous enrollment provision prevented insurance churn.18 Churn refers to a short period of time when Medicaid beneficiaries experience distribution in coverage. The number of individuals enrolled in Medicaid programs around the nation grew by 21.8 percent (71.2 million to 86.7 million) between the beginning of 2020 and the end of 2021.19 While income and employment changes stemming from Covid-19 aided in the increase in Medicaid enrollments, the retention of Medicaid beneficiaries was the primary force behind the increase in enrollment numbers.20

“Unwinding” refers to the period of time when the Medicaid provisions under the Covid-19 public health emergency come to an end and those no longer eligible for Medicaid coverage transition to other insurance plans.21 A phase-down of the increased federal dollars going to states for Medicaid programs has begun due to the ending of the COVID-19 public health emergency. The CMS identified the unwinding process as having two phases. Phase 1 consists of the preparation of the renewal for Medicaid’s new eligibility process and making individuals aware of the changes to the continuous enrollment provision.22 CMS is requiring states to develop and submit plans for how they will conduct this process and their timeline for doing so. Phase 2 consists of transitioning Medicaid participants to some sort of coverage whether it be Medicaid or other coverage plans.23