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Medicaid Unwinding – Return to Regular Medicaid Redetermination: Ensuring Resident Medicaid Coverage

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Since March 2020, States ceased Medicaid eligibility determinations and have been unable to disenroll any Medicaid beneficiaries from the Medicaid program.  The freeze on redeterminations and prohibition on disenrollment were based upon federal statutory requirements States had to meet to receive the increased federal Medicaid funding of 6.2% over the course of the pandemic.  Now, with the Public Health Emergency (PHE) ending, States are returning to “regular” Medicaid redeterminations schedules. 

Why This Matters
  • States – State Medicaid Agencies have over 87 million redeterminations to conduct before May 2024.  Most states have not conducted redeterminations in over three years.  Over that period, beneficiary information has become out of date (contact information, financial information, etc.) and State Agencies have had significant staff turn over and shortages.  In many States, their State and/or County eligibility units may have few or no staff with redetermination expertise.  Despite CMS guidance and support, this could result in notable breaks in Medicaid coverage; and
  • Providers – If a beneficiary loses Medicaid eligibility, Medicaid payments stop, and beneficiaries have very clear protections in federal law for when these breaks occur despite the loss of Medicaid payments.  Additionally, while at first glance waves of nursing facility (NF) and assisted living (AL) Medicaid redeterminations may seem of little concern, it is probable that the following are problematic: a) staff turnover in NF and AL business offices resulting in little to no Medicaid redetermination experience; and b) while older adult and persons with disabilities functional criteria to meet Medicaid Levels of Care are highly unlikely to change, the people involved with managing their finances likely have changed. 

For a more in depth discussion of Medicaid Unwinding, click here.

AHCA/NCAL Resources

The Association has prepared an array of resources aimed at supporting NFs and ALs to manage significant numbers of Medicaid Redeterminations.  Working with partner organizations, AHCA/NCAL has developed three modules and related tools. 

Disclaimer – Of note, these materials do not constitute business or legal guidance.  They are for general education and planning efforts, only.  For in depth support, please contact your information technology contractor, third party consultants or attorneys.

Course Outline:
  • Module 1:  Medicaid Unwinding – Provider Action Steps and Tools
  • Module 2: Financial Care Plan Development and Management
  • Module 3:  Medicaid Application Development and Submission
This course is free to AHCA/NCAL members only. 
Follow the instructions below to register. 
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Need further assistance? Email educate@ahca.org

A certificate of completion will be available upon completion. There are no CEs available for this training. 


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All Medicaid Unwinding – Return to Regular Medicaid Redetermination: Ensuring Resident Medicaid Coverage materials subject to this copyright may be photocopied or distributed for the purpose of nonprofit or educational advancement. The use, photocopying, and distribution for commercial purposes of any of these materials is expressly prohibited without the prior written permission of American Health Care Association.

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