Medicaid Directors: Uncertainty About Public Health Emergency ‘No Longer Tenable’
The National Association of Medicaid Directors (NAMD) has written a letter to congressional leaders seeking clarity around when and how the COVID-19 Public Health Emergency (PHE) will end. The lack of clarity about whether there will be another extension “exacerbates the uncertainties for state planning to resume normal Medicaid operations,” the letter states.
Since there was no announcement from the U.S. Department of Health & Human Services that the PHE will end in January 2023, states are now assuming the PHE will extend into April 2023.
“The uncertainty around the PHE is no longer tenable,” the letter said.
NAMD, a bipartisan, nonprofit, professional organization representing leaders of all Medicaid agencies across the country, is urging Congress “to mitigate this years-long uncertainty and provide firm commitments for states on timing and resources.”
Without a date certain, the letter explains, states are unable to develop their Medicaid budgets with any degree of certainty. “This creates immense variability in budget scenarios and erodes Medicaid leaders’ credibility with their governors and legislatures. It also inhibits the ability for state and county eligibility entities to know when to deploy staffing resources. In the worst-case scenario, this could lead to state Medicaid agencies not having state-allocated resources at a level to appropriately manage the redetermination period or even having to implement benefit or rate reductions to manage the shock of federal resources falling away.”
Specifically, NAMD is asking Congress to:
• Provide certainty on when Medicaid coverage redeterminations will begin, with at least 120 days advance notice;
• Provide certainty that existing federal guidance on the redetermination period will not change;
• Provide certainty on available financial resources during the redetermination period, specifically by maintaining the current 6.2 percentage point FMAP (Federal Medical Assistance Percentages) enhancement through the first quarter of redeterminations and phasing the enhancement down over 12 months after this quarter; and
• Provide certainty that underlying Medicaid eligibility rules will not change during the redetermination period.
The most critical thing Congress can do to ensure a successful unwinding from the PHE, the letter states, is provide clear dates and funding levels in statute for state Medicaid agencies to reliably plan around. “This certainty will allow states to make confident budget projections, solidify the content and timing of messages that go out to Medicaid’s stakeholders, and will ensure the highest possible degree of appropriate coverage retention for people being served by the program – whether that is remaining on Medicaid or transitioning to other sources of coverage for which they are eligible.”
NAMD goes on to remind Congress of the major challenges facing the Medicaid delivery system because of the pandemic. “Workforce challenges are acute across most sectors of the healthcare system, and are particularly pronounced in skilled nursing, behavioral health, and direct service workers providing Medicaid-funded home- and community-based services. Simultaneously, demand for Medicaid services is growing, in part because of the continuous enrollment requirement as well as national demographic changes. Federal investments to stabilize Medicaid’s critical provider infrastructure should be considered, potentially within the context of action to support state redetermination efforts.”
The letter is signed by Allison Taylor, NAMD board president and director of Medicaid for the Indiana Family and Social Services Administration, and Cindy Beane, NAMD board president-elect and commissioner of the West Virginia Department of Health and Human Resources.
