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Are you prepared for the end of the COVID PHE?


October 11, 2022

On January 31, 2020, the Department of Health and Human Services declared a Public Health Emergency (PHE) in response to COVID-19. The impact has been immense. Enrollment in Medicaid and the Children’s Health Insurance Program (CHIP) has grown by 23.4%, powered by continuous enrollment policies during the PHE. As of March 2022, 87.9 million people are enrolled across the programs.

The PHE afforded new flexibilities that have helped millions of struggling households gain easier access to critical federal nutrition programs. That includes the Special Supplemental Nutrition Program for Women, Infants and Children (WIC) and the Supplemental Nutrition Assistance Program (SNAP). In addition, through Pandemic Electronic Benefit Transfer (P-EBT), millions more eligible children are receiving temporary emergency nutrition benefits loaded on EBT cards for buying food.

As of now, the PHE is slated to end October 13, 2022. However, the Department of Health and Human Services did not provide states with 60 days’ notice in August. As of this writing, the end date remains unclear however it is anticipated that it will be renewed through at least January 2023.

What we do know is that when the PHE ends, states will have 12 months to initiate renewals for their caseload and 14 months to redetermine eligibility. Already, the Centers for Medicare and Medicaid (CMS) are asking states to develop formal operational plans for managing the PHE wind-down. Those plans need to include robust communications to reach as many beneficiaries as possible.

What’s at stake as the Public Health Emergency comes to a close?

For Medicaid alone, as many as 14 million to 16 million people are expected to lose coverage as the PHE ends. Many eligible individuals will need to re-enroll in Medicaid or shift to a Marketplace plan. Unless states undertake formal outreach initiatives, some of these people will not complete this critical process.

Congress has authorized P-EBT until the end of the PHE—including during the summer of the school year in which the PHE concludes. After that? Children from families with low incomes will lose these additional nutrition benefits. Similarly, when the PHE ends, most SNAP participants are expected to lose $82 in SNAP benefits.

In other words, states are facing an avalanche of eligibility demands on resources that often are already stretched thin.

Several states are taking proactive steps to prepare. One earmarked funding to help people no longer eligible for Medicaid transition to marketplace coverage. Another set up a call center to help Medicaid enrollees update contact information.

Start preparing across three areas: operations, IT and outreach strategies

Several states are taking proactive steps to prepare. One earmarked funding to help people no longer eligible for Medicaid transition to marketplace coverage. Another set up a call center to help Medicaid enrollees update contact information. Other tactics include launching a new website and establishing a hotline and webpage where clients can update information. On the communications front, one state conducted a digital ad campaign that more than doubled the number of enrollees who completed their renewals.

Those are strategies and tactics worth emulating. In addition, as the end of the PHE approaches, we see opportunities across three key areas:

1. Process and operations. Look for ways to streamline renewal and transition processes. That may include coordinating with marketplaces to establish systems for facilitating and activating coverage. It may involve investments in customer service infrastructure to prepare for increased calls and requests for help.

2. Workforce solutions. Redetermining eligibility at this speed and scale will place a massive burden on already-strained state caseworkers. Think through how your state could tackle that challenge. Will you entice retirees to come back on a short-term basis? Could you explore the use of contractors or set up flexible programs to engage? In addition to human resources, perhaps there are some rapid-cycle automation solutions that could help. One relatively simple example: using internal and external data sources to prepopulate consumers’ applications and conduct preliminary eligibility determinations.

3. Outreach strategies. Though often siloed, SNAP and Medicaid agencies typically serve the same population. As you plan outreach strategies, consider how you might coordinate a single messaging platform and single opt-in for both programs. Beyond that, review existing consumer communications and website language. Is it clear about the upcoming renewal process, required actions and coverage changes? Tactically, build a plan for engaging audiences in a variety of ways.

Many states have started to use proactive two-way SMS messaging to engage customers throughout their benefits journey. Today, states are using proactive messaging for a number of purposes. That includes providing SNAP customers with clear directions for renewing their benefits; simplifying the P-EBT process by answering parents’ questions; and driving customers to complete renewal requirements digitally to accelerate state processing times. These examples are using artificial intelligence to provide a personalized experience that doesn’t require human staffing. These capabilities are changing the way states think about the one-way “blast” messaging of the past.

The PHE enabled new, more flexible approaches to delivering health and human services. As we all prepare for the wind-down, states can use this moment to rethink and reshape how they support their citizens and residents in the future. With thoughtful improvements to processes, technology and engagement strategies today, they can create a brighter tomorrow.

As your state continues preparing, reach out to me via LinkedIn.


Heidi Reed

Managing Director - Health & Public Service, Integrated Eligibility