CMS opens ACA special enrollment period for those losing Medicaid coverage

CMS opens ACA special enrollment period for those losing Medicaid coverage

The Centers for Medicare and Medicaid Services is opening a special Affordable Care Act enrollment period for beneficiaries losing Medicaid or Children’s Health Insurance Program coverage due to the end of the continuous enrollment requirement.

CMS on Friday released information on a temporary Exceptional Circumstances Special Enrollment Period from March 31 through July 31.

Marketplaces using the federal platform will be providing additional flexibility for eligible consumers to enroll in coverage during and immediately following the end of the Medicaid continuous enrollment condition unwinding period, CMS said. This starts on April 1 as states begin redeterminations.


Up to 18 million people are projected to lose Medicaid coverage as the continuous enrollment requirement put in place under the public health emergency ends.

The Families First Coronavirus Response Act prevented state Medicaid agencies from disenrolling people during the PHE.

The omnibus spending package that passed at the end of 2022 gave states a heads up on Medicaid coverage. Under the bill, states will be able to begin processing Medicaid redeterminations on April 1, whether the PHE is in place or not.

This previously left the question of whether disenrollment from Medicaid met the conditions of a “qualifying event” to enroll in in health insurance under the ACA without waiting for open enrollment to begin in November.

CMS’s guidance on Friday aims to close any gaps in coverage, for a smooth transition from one type of health insurance to another.

In the letter, CMS said it is providing additional flexibilities for states and marketplaces during the unwinding period to help beneficiaries maintain continuity of coverage as they transition off Medicaid or CHIP into a marketplace qualified heath plan.

The current public health emergency ends on April 11. If the PHE is not continued, as is expected, providers will get their promised 60 days’ notice on February 10.


On December 19, 2022, 25 governors sent a letter to President Biden asking him to end the public health emergency in April as a continuation of the PHE would negatively affect states financially by having to increase their non-federal matching funds to cover the Medicaid population .

CMS on Friday released a state health official letter outlining new requirements in the Consolidated Appropriations Act, 2023, that impact state activities for Medicaid and CHIP regarding the Medicaid continuous enrollment condition.

The SHO letter also addresses changes to the other conditions states must meet to receive increased federal medical assistance percentage, as well as reporting requirements and new enforcement authority, for CMS to ensure state compliance.

Twitter: @SusanJMorse
Email the writer:

Leave a Comment

Your email address will not be published.