Some BadgerCare participants might need new insurance when health emergency ends

While the COVID-19 pandemic continues — and with it a federal health emergency — Wisconsin’s 1.5 million Medicaid recipients have guaranteed coverage. When the emergency expires, they and the people who run the program will confront a new challenge: making sure everyone stays covered.

After the federal public health emergency was declared in early 2020, Congress passed the Families First Coronavirus Response Act, the nation’s first COVID-19 relief legislation. The act provided states with an extra infusion of federal cash for Medicaid — about $50 million a month for Wisconsin, said Jim Jones, the state’s Medicaid director, in an interview with the Wisconsin Examiner. 

In addition, states were also required to guarantee continuous coverage for people already on Medicaid or those who subsequently enrolled in it during the emergency.

The continuous coverage guarantee suspended a rule that requires Medicaid participants to re-enroll every year and to report changes in their personal circumstances — including changes that could make them ineligible in normal times, typically increases in income.  

The continuous coverage rule helped foster an “unprecedented” increase in Medicaid enrollment nationwide, the Urban Institute and the Robert Wood Johnson Foundation stated in a Sept. 15 report. That rule will end, however, when the federal public health emergency expires.

Now the Department of Health Services (DHS), which administers Medicaid’s many programs funded by federal and state dollars, must plan ahead to ensure “the smooth transition to that post-Public Health Emergency world,” said Jones.

“It’s just so important that people maintain that health coverage,” Jones said. “Having that coverage, and having access to preventive care, are incredibly important to keep people healthy.”

The current extension of the emergency, signed in July, runs through late October, although it is expected to be renewed again. But when the emergency does eventually expire, and the continuous coverage guarantee ends with it, the Urban Institute projects that as many as 15 million people who are on Medicaid currently could lose their eligibility.

One in 10 leave

Before the pandemic, an average of about 10% of people enrolled in Medicaid would leave the program when it was time to renew, although that would vary from month to month, Jones said.

DHS reports show that since March 2020, Wisconsin’s total Medicaid enrollment has risen 25% to almost 1.5 million people who were covered in August 2021.

A few of those were elderly people and people with disabilities covered by Medicaid’s long-term care programs, and other specialized forms of Medicaid coverage. But most of them joined through BadgerCare, the program that covers doctors and hospital care for families with children as well as childless adults. BadgerCare added nearly 260,000 people — a 33% increase.

BadgerCare is also where the continuous coverage guarantee is likely to have the biggest impact when it ends.

People who leave Medicaid do so for many reasons on their own — to buy health insurance on the private market, for employer-provided health coverage or perhaps because they’ve reached the age to qualify for Medicare, the federal health insurance plan for the elderly.

“For a lot of our people, [BadgerCare] is a temporary adjustment where they’ve lost a job or whatever it might be,” Jones said. “It’s meant to help working people who are below the poverty line as well, but it is a program that is designed in many cases to be temporary, at least for families and childless adults.”

One of the most common reasons that some people become ineligible for Medicaid is higher income. With some exceptions, BadgerCare is limited to people with household incomes at 100% or less of the poverty guideline, which changes with household size (see table).

If a household adds another income-producing member, or an existing income-earner works longer hours or gets a raise, that can put the whole household over the ceiling.

With the continuous coverage guarantee, that rule currently does not apply. Once the health emergency ends, and with it the guarantee, people over that ceiling will no longer qualify for BadgerCare.

Planning the transition

DHS is currently making its plans assuming that the emergency will expire at the end of 2021, Jones said, “but if it doesn’t, our plans will still go forward based on whenever that ending is.”

The Centers for Medicare and Medicaid Services (CMS) in the federal Department of Health and Human Services (HHS) has told state Medicaid programs that they’ll have at least 60 days’ advance notice of the end of the emergency, according to Jones. CMS has also sent states guidance for how to carry out the “unwinding” of policies that temporarily expanded Medicaid eligibility in the pandemic.

Because of the federal continuous coverage guarantee, DHS doesn’t have enough information from people on BadgerCare to know whether their eligibility has changed, Jones said. When the emergency ends, all Medicaid participants will have to resume the annual renewal process and be requalified by the state. The federal government has told state officials they will have up to a year to complete that renewal.

Jones said the agency is communicating with Medicaid managed care plans and community health centers that receive federal aid about preparing for the transition. His office also works with Covering Wisconsin, which serves as a health care navigator to help people figure out how to get individual coverage they can afford through the federal insurance marketplace set up through the Affordable Care Act (ACA).

For people who make more than the federal poverty ceiling that qualifies them for BadgerCare, the state’s Medicaid program will transfer their information to the ACA marketplace to help them get appropriate subsidies and tax credits to make the premium costs more affordable, Jones said.

CMS has told the DHS staff that no one should be removed from the program until their eligibility has gone through the full examination, relying on new and updated information. “It’s not as though we can just look at the data that we have in our system today and then just go, ‘Oh, you’re not eligible,’” Jones said.

DHS is urging people who are on BadgerCare as well as those enrolled in any of the other Medicaid programs to make sure that all of their contact information is up to date, including mailing addresses, phone numbers and email addresses. They can update that information online or with their Medicaid caseworker, according to DHS.

Participants also will need to watch their mail in the coming months for information about the resumption of the formal renewal process, Jones added, and to respond promptly.

“Our goal here is to make sure that people maintain coverage for which they’re eligible,” said Jones. And if they are not eligible, “we want to make sure that they transition to private health insurance. We don’t want people to go uncovered.”