In a recent development, the Centers for Medicare & Medicaid Services (CMS) and the Departments of Labor (DOL) and the Treasury have issued a letter urging employers, plan sponsors, and carriers to consider extending the enrollment period for employer-sponsored health plans. This extension is aimed at helping individuals who have lost their Medicaid and Children’s Health Insurance Program (CHIP) coverage due to the resumption of normal eligibility and enrollment procedures.

Traditionally, Medicaid coverage requires annual renewal of eligibility. However, during the COVID-19 Public Health Emergency, these renewal requirements were temporarily halted to prevent members from losing their coverage. Unfortunately, this pause in eligibility rules came to an end on March 31, 2023, as stipulated by the Consolidated Appropriations Act of 2023.

As Medicaid agencies across the nation revert to their normal eligibility and enrollment processes, they are reviewing coverage eligibility for all individuals under Medicaid and CHIP. With the return to the pre-COVID procedures, many individuals are finding themselves ineligible, resulting in a loss of Medicaid or CHIP coverage. The Departments emphasize that this situation poses unique challenges:

“Given the exceptional circumstances surrounding the resumption of Medicaid and CHIP renewals for the first time in three years, many individuals will need more than the typical 60-day window after the loss of Medicaid or CHIP coverage to apply for and enroll in other coverage. For example, employees may not realize that they lost their Medicaid or CHIP coverage until they access care, since they may have missed notices from their state agency, and then missed their opportunity to enroll in other coverage.”

To address this loss of coverage, CMS has implemented a temporary special enrollment period. This period allows individuals who lose Medicaid or CHIP coverage between March 31, 2023, and July 31, 2024, to enroll in individual coverage on Healthcare.gov. It’s essential to note that this special enrollment period applies exclusively to enrollments on Healthcare.gov and does not extend to group health plans.

If you want to delve deeper into this topic and access the complete information, please download the PDF

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