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Update on Unwinding the Continuous Coverage Requirement: State Panel Discussion

During the past year, the Commission has been engaged in ongoing discussions about unwinding the continuous coverage provisions in Medicaid once the COVID-19 Public Health Emergency (PHE) ends. In particular, the Commission is focused on the potential risk of eligible individuals inappropriately losing coverage as states resume redeterminations, as well as state administrative and system capacity to handle redeterminations.

The Consolidated Appropriations Act of 2023 (CAA, P.L. 117-328) delinks the end of the continuous coverage requirement from PHE and phases down the enhanced federal matching rate to states over the remainder of 2023. The CAA also places specific redetermination processing and data reporting requirements on states.

This state panel provided an update on how states are now thinking about the unwinding of the continuous coverage requirement in light of the passage of the CAA.

Panelists included:

  • Chris Underwood, chief administrative officer, Colorado Department of Health Care Policy and Financing;
  • Traylor Rains, state Medicaid director at the Oklahoma Health Care Authority; and
  • Sandie Ruybalid, deputy administrator, Nevada Division of Health Care Financing and Policy.


* panelists did not have slides.