During the COVID pandemic, states have not disenrolled anyone from Medicaid, even if they’re no longer eligible or failed to respond to a renewal packet. This continuous coverage provision was in effect from March 2020 through March 2023.
Starting April 1, 2023, states can resume disenrollments (some states will not have their first round of disenrollments until May or June, depending on when they begin their eligibility redeterminations). An estimated 15 million people are expected to lose Medicaid during the 14-month “unwinding” process. Most will be eligible for employer-sponsored coverage or coverage in the exchange/marketplace. But some will be eligible for Medicare.
Although Medicaid expansion eligibility ends when a person turns 65, people have not been disenrolled from Medicaid due to aging out of the program during the pandemic. So a person with Medicaid expansion coverage who turned 65 between March 2020 and March 2023 was not disenrolled from Medicaid unless they requested disenrollment or moved out of the state.
These individuals will be able to transition to Medicare, and will have a special enrollment period that will allow them to do so without any late enrollment penalties. The details are in a final rule that CMS issued in late 2022 (see Section 406.27(e)).
The special enrollment period begins when the person is notified that they’re no longer eligible for Medicaid (which will happen before the Medicaid coverage is discontinued), and continues for six months after Medicaid ends. And people who use this special enrollment period have an opportunity to have their Medicare coverage begin retroactively back to the day after their Medicaid ended, although Medicare premiums would also have to be paid back to that date.