Preparing for Medicaid Changes When the Public Health 

Emergency Expires

Fact Sheet Published April 5, 2022

Government agencies have started reviewing policies that were put in place to meet the needs of states, 

localities, and the public during the height of the COVID-19 pandemic. When the federal declaration of a public 

health emergency (PHE) expires, many of the flexibilities initiated during the PHE will need to be rolled back. This 

return to pre-pandemic operations will have far-reaching impacts for older adults and people with disabilities. 

Changes in Medicaid enrollment and eligibility will be particularly important—and potentially confusing or 

disruptive—for current enrollees. The aging and disability networks can prepare in advance for the coming 

changes to best meet the needs of people who rely on Medicaid coverage for essential services and supports. This 

fact sheet will help address some common questions ACL grantees may have. 

What temporary federal and state Medicaid changes were made to respond to the COVID-19 pandemic and 

Public Health Emergency?

The Families First Coronavirus Response Act (FFRCA), signed into law March 2020, provided states with an

increase in the amount of federal funding contributed to their Medicaid programs provided they agreed to certain 

requirements surrounding Medicaid eligibility and enrollment. In exchange for accepting the extra federal dollars, 

FFRCA prohibited states from disenrolling anyone from their Medicaid programs (with limited exceptions). For 

example, states could not disenroll individuals due to an increase in income or change in “categorical eligibility” 

(e.g. pregnancy, age, disability) that would ordinarily make them ineligible for Medicaid. This continuous coverage 

provision included in the FFCRA is not indefinite and will end with the public health emergency.

When will the public health emergency end and what does that mean?

The PHE was declared on January 27, 2020 and has been reauthorized several times. While the Biden 

Administration has not officially said when the PHE will end, it has assured states that they will receive at least 60 

days of advance notice. Upon the end of the PHE, states will have 12 months to evaluate the eligibility of virtually 

everyone in their Medicaid programs to make sure they still qualify for the program. This will present a lot of work 

for states and CMS has released new materials to help states prepare.

Five Things our Networks Should Know:

1) Medicaid beneficiaries should make sure their Medicaid agency has their current contact information. 

They should check their mail and be sure to mail back any Medicaid forms they receive.

Making sure Medicaid agencies have the correct mailing address, phone number, and email address for all 

enrollees will ensure renewal and other eligibility paperwork gets to the right place. Each state’s Medicaid website

will have instructions for how to check an enrollee’s contact information and update it if necessary. The state 
Medicaid agency will reach out to Medicaid enrollees via mail to either confirm coverage is renewed or provide a 

renewal form to complete. Beneficiaries may also hear from their Medicaid managed care plan, social service 

provider, or health care provider with reminders, updates, and information. 

2) All renewal forms and notices must be accessible to people with limited English proficiency and people 

with disabilities.

By law, Medicaid renewal information should be provided in plain language and in a way that is accessible to 

people with limited English proficiency and people with disabilities. Information from the Medicaid agency should 

be available in multiple languages and with free oral translation. For people with disabilities, states should provide 

appropriate auxiliary aids and services at no cost. This could include sign language interpretation and materials in 

braille or other accessible alternative formats.

3) Many people who are no longer eligible for Medicaid will have other coverage options.

As states perform renewal and redetermination actions for people with Medicaid, they will work to ensure people 

who are still eligible for Medicaid stay enrolled and those that may qualify for a private Marketplace plan are 

transitioned smoothly. For example, someone who no longer meets eligibility requirements for the Medicaid 

category they applied under initially may qualify under a different Medicaid category. State Medicaid agencies are 

required to automatically assess whether this is the case. Additionally, many people no longer eligible for 

Medicaid can enroll in an affordable Marketplace plan. The Medicaid agency is required to transmit eligibility 

information directly to the Marketplace and, because losing Medicaid is a Qualifying Life Event, individuals will be 

able to enroll outside a regular enrollment period. 

Some older adults and people with disabilities have become eligible for Medicare over the last two years and, 

because they had Medicaid coverage, may have decided not to enroll in Medicare thinking they did not need it. 

Now they may be outside a Medicare enrollment period. In addition, some people with both Medicare and 

Medicaid may lose Medicaid and thus no longer be eligible for their Medicare Advantage plan (also called Dual 

Eligible Special Needs Plans or D-SNPs). Beneficiaries in these types of situations will need special counseling, 

including information on Medicare enrollment periods, penalties, and Medicare Advantage plan options. People 

with questions about their Medicare coverage should be referred to their State Health Insurance Assistance 

Program.

4) If someone is disenrolled or their Medicaid coverage changes and they disagree with their state 

Medicaid agency’s decision, they can appeal.

Medicaid beneficiaries who have their benefits mistakenly terminated or their eligibility reduced have the right to 

an appeal, also called a “fair hearing,” to contest the state Medicaid agency’s decision. In general, individuals can 

keep their Medicaid coverage while this hearing is pending. Because the continuous coverage provisions were due 

to a change in law, losing Medicaid on the basis of the PHE ending and the FFRCA’s continuous coverage 

provisions sunsetting is not a valid basis to request a fair hearing. However, Medicaid beneficiaries that believe 

the decision to disenroll them from the program was due to error can request an appeal. For example, someone 

who believes the Medicaid agency did not correctly assess their income or disability status can appeal their state’s 

decision. People over the age of 60 may want to contact the Eldercare Locator for referral to a free legal services 
program funded under the Older Americans Act. Similarly, people with disabilities may be able to receive 

assistance from local legal aid organizations, including Protection and Advocacy systems. The Disability 

Information and Access Line (DIAL) can help make referrals to these services.

5) The end of the Public Health Emergency may lead to an increase in utilization of services provided by 

Older Americans Act programs, Centers for Independent Living, Assistive Technology Act programs, and 

other ACL grantees.

While some people will stay on Medicaid or be transitioned to other coverage, other people will lose Medicaid 

coverage and the supports and services it provides. This could mean a greater reliance on programs offered by the 

aging and disability networks. ACL grantees can begin to prepare now by assessing capacity and evaluating how to 

best meet an increased need for services. Grantees may find it helpful to stay in contact with their state’s 

Medicaid agency for the latest on the PHE unwinding timing and process, opportunities for collaboration, and 

Medicaid renewals and other eligibility determination actions.

The upcoming changes to Medicaid are historic and the aging and disability networks are critical partners in 

ensuring older adults and people with disabilities can continue to receive the supports and services they need 

without disruption. 

Find additional resources from Medicaid.gov including communication tools.