Unwinding Plan for the End of the Medicaid Continuous Coverage Requirement and Resumption of Normal MaineCare Eligibility Operations

Background

The U.S. Department of Health and Human Services (HHS) declared a federal public health emergency (PHE) due to the Coronavirus Disease 2019 (COVID-19) on January 27, 2020. In response, the Maine Department of Health and Human Services implemented temporary changes to MaineCare (Maine’s Medicaid program) eligibility and enrollment procedures under a variety of federal and state authorities to ensure access to critical health care benefits during the PHE. 

In accordance with the Families First Coronavirus Response Act (FFCRA), which authorized enhanced federal funding for Medicaid, the vast majority of MaineCare members’ benefits remained open to provide continuous coverage during the PHE. As a result, MaineCare enrollment has grown almost 40% since February 2020.

In December 2022, Congress passed the Consolidated Appropriations Act of 2023, which included a provision separating the Medicaid continuous coverage requirement from the COVID-19 public health emergency by providing a fixed end date of March 31, 2023.

Starting in April 2023, states are expected to resume routine eligibility and enrollment operations, including disenrolling MaineCare members who are no longer eligible for coverage and those states cannot demonstrate are eligible. States have 12 months from April 1, 2023 to initiate redeterminations for all enrolled members. This period is referred to as the PHE “unwinding.”

The Department anticipates the end of the FFCRA continuous coverage requirements will significantly impact MaineCare enrollment. The Department’s primary goal is to maximize continuity of coverage for MaineCare members throughout the unwinding, and to connect disenrolled individuals with the state-based Health Insurance Marketplace (CoverME.gov). Many of these individuals would still be eligible for coverage through CoverME.gov or once they get back in touch with MaineCare.

This document outlines the Department’s approach, communications and outreach plan, and key dates related to a return to routine eligibility and enrollment operations.

Unwinding Approach

Under the continuous coverage requirements in the FFCRA, Maine has been required to maintain enrollment of nearly all members through the end of the month in which the PHE ends. The omnibus appropriations bill for 2023 will lift the continuous coverage protections and delinks them from the public health emergency. This new law starts the unwinding process and requirement to conduct full redetermination for all MaineCare members on April 1, 2023.

Preparation for the End of the Continuous Coverage Requirement

The Department has taken the following actions to prepare for the end of the continuous coverage requirement:

  • Continued issuing and processing MaineCare renewals throughout the PHE to keep case information as up to date as possible
  • Developed enhanced standard operating procedures to ensure the ability to record telephonic signatures for all renewals and applications
  • Launched My Maine Connection, a new online portal to apply for benefits, renew current benefits, report changes, submit verifications, request MaineCare cards, and enroll in electronic noticing
  • Contacted members who have had mail returned to the Department as undeliverable
  • Developed text messaging and email options to alert members of upcoming renewals
  • Developed a communication plan to request updated contact information, including conducting outreach to member’s who may need to update their information
  • Published online resources for MaineCare members and stakeholders, including unwinding plans and Frequently Asked Questions
  • Partnered with community-based organizations to provide a point of contact for direct assistance to MaineCare members.
  • Established a 15-month CoverME.gov Special Enrollment Period that coincides with the redetermination process to allow MaineCare members to easily explore plan options and enrolling affordable Marketplace coverage. 

Renewal Plan

Beginning in May 2023, OFI will redetermine eligibility for an estimated 17,000 households, representing approximately 31,000 members, each month.

Renewal forms will be sent on the 21st of the month prior to the month it is due. For example, if the renewal is due July 31, 2023, the renewal form will be sent (and available on My Maine Connection) on June 21, 2023.

Some members who have not updated their case records by the end of their eligibility period and are likely to change coverage, such as some members enrolled in CubCare or Medically Needy, will be scheduled for renewal within 3 months of the continuous coverage requirement ending on March 31, 2023.

OFI schedules renewals by household, 12 months after the start of benefits or the application month. The household’s renewal date is in the upper right-hand corner of Notices of Decision sent from the Department.

For members who use the online portal at www.mymaineconnection.gov, a “Renew Benefits” button will appear on their dashboard when it’s time to renew.

Member Communication Plan

OFI will send members three mailings regarding their renewal:

  1. Renewal Reminder Notice In the quarter prior to the scheduled renewal, OFI will send a reminder notice to alert the member of the upcoming renewal requirement and to encourage them to update their contact information (see sample notice below). Members who provided a cell phone number or email address will also receive similar reminder messages through text or email.
  2. Renewal Form This is a pre-populated paper renewal form will be mailed in an envelope with a blue striped with a postage paid return envelope at least 30 days prior to the renewal due date. If it’s blue, it’s time to renew! Members who signed up for e-notices will get an email or text when it is time for their renewal.  
  3. Notice of Decision
    1. If the member completes their renewal timely and remains eligible, a notice of decision will be issued to explain ongoing coverage.
    2. If the member completes their renewal timely and no longer qualifies, a notice of decision will be sent at least 15 days before the date coverage is set to end. If the individual may be eligible for coverage through the Marketplace, their information will be sent to CoverME.gov.
    3. If the member does not complete their renewal by the due date, a closure notice will be sent on the first of the month following month the renewal was due. Coverage will end the last day of the month following the month the renewal was due. The member will have 90 days from the date MaineCare coverage ends to complete their renewal and see if coverage can continue.

The first members to go through the redetermination process will be those scheduled for renewal in May 2023.

For example, May renewals are issued on April 21, 2023. OFI will begin eligibility redeterminations for members with May renewals in April as members return renewal forms. If a member with a May renewal does not return the renewal by May 31, 2023, MaineCare will close their coverage effective June, 2023. 

An example of the timeline for the MaineCare eligibility redetermination process. April renewals are issued on March 21, 2023. OFI will begin eligibility redeterminations for members with April renewals in March as members return renewal forms. If a member with an April renewal does not return the renewal by April 30, 2023, MaineCare will close their coverage effective May 31, 2023.

 

Resumption of Standard Eligibility Operations Effective May 1, 2023

In addition to this process to redetermine the eligibility for all MaineCare members described above, the Department implemented a number of eligibility- and enrollment-related programmatic flexibilities in response to the PHE, which will also be phased out beginning on May 1, 2023 as follows.

Eligibility Changes

  • Premiums will resume for certain coverage groups. Premium payment will be required for members enrolled in Katie Beckett, Special Benefits Waiver, or MaineCare for Working People with Disabilities after the household has completed their annual renewal. The Department has not sought unpaid premiums during the period of the PHE (starting January 2020). Failure to pay premiums after renewal may result in a loss of coverage.
  • Verification of financial factors will be required at application, renewal, or reported change if the Department is unable to verify income through electronic data sources.
  • Medically Needy deductibles will start again. Individuals who met a deductible to gain MaineCare coverage on or after March 18, 2020, may have had coverage continue past the deductible period (deductibles are typically six months). OFI will redetermine eligibility for these members to determine new deductible amounts for them.

Maximizing Continuity of Coverage

Along with planning for the resumption of standard eligibility operations as described above, the Department facilitates application transfers to CoverME.gov, Maine's Health Insurance Marketplace, for people no longer eligible for MaineCare. CoverME.gov will also be conducting targeted outreach to those consumers, sending a series of “Welcome to CoverME.gov” marketing materials via postal mail. Emails, calls, and texts will be incorporated as well, based on availability of contact information. A CoverME.gov Special Enrollment Period for loss of MaineCare coverage will be available for 15 months, from April 15, 2023 until July 31, 2024, to coincide with the redetermination process.  

COVID-19 Testing and Treatment for Uninsured

As part of its public health emergency response, the Department offered a special coverage group for uninsured individuals that provides a limited benefit package related to testing, diagnosis, treatment of and vaccination for COVID-19 during the PHE period. To be eligible for the COVID-19 uninsured coverage group individuals must be a Maine resident, a U.S. citizen or eligible immigrant, and uninsured. There is no income or resource test for this coverage.

Coverage in the COVID-19 uninsured coverage group ended on May 11, 2023, the same date the PHE ended. Applications will continue to be accepted to cover a retroactive period (up to three months prior to the PHE end date), but coverage will not be available after May 11, 2023. 

Individuals enrolled in this coverage group will receive a closure notice prior to the end of the PHE with the option to apply for full MaineCare coverage.

Communication and Outreach