PHE Program Integrity: The Downside of Frozen Rosters

In 2020, Congress enacted the Families First Coronavirus Response Act (FFCRA). The FFCRA offered states additional federal funding in exchange for a requirement to keep Medicaid program beneficiaries continuously enrolled until the end of the COVID-19 Public Health Emergency (PHE).

The FFCRA eliminated the typical enrollment churn of beneficiaries. Some examples of this include individuals who moved outside the paying state or whose income growth or household composition changes eliminated their continued eligibility to receive taxpayer-provided benefits. 

1. Enformion’s population surveys have revealed that an average of 11.43% of families relocated annually during the pandemic, with as many as half of them moving to another state. 

2. A KFF study shows that the total Medicaid/CHIP enrollment grew to 90 million in July 2022, an increase of 18.7 million, or 26.3%, since February 2020. 

3. When the PHE ends, the current increased enrollment should reverse and the uninsured population will rapidly rise. The lack of proper tracking of the offramp situations will exasperate challenges for states’ public health programs.  States with lax enrollment eligibility standards for program integrity may see their Medicaid populations rise even further. 

Frozen rosters impact eligible beneficiaries to obtain quality services. States should have a well-planned solution for quarterly verification of continued eligibility and a managed offramp to minimize the impact of restarting the legislatively required program integrity operations. Contact us today to see how Enformion can help.