What the end of the COVID Public Health Emergency would mean for Texas

Toward the beginning of the COVID-19 pandemic, the Federal government passed legislation providing additional funding for state Medicaid programs so long as the state agreed not to disenroll anyone. As federal officials begin signaling an end to the Public Health Emergency, Texas must prepare for the impact this will have on Medicaid enrollment and finances.  

During the public health emergency, Texas’ Medicaid rolls increased dramatically – by over 1.3 million people.  

Populations Comprising Medicaid Enrollment Growth

In November 2019, Children comprised nearly 3 out of every 4 (73%) Medicaid enrollees.  Disability-related and Aged & Medicare-related each comprised about 10% of enrollment, with the bulk of the rest split between extremely-low-income parents (an individual’s income would need to be below $3500 per year) and pregnant women.  

Today, the program with the largest relative growth is Pregnant Women, with smaller relative increases in Children and Parent groups. Aged & Medicare-related and Disability-related groups saw small relative decreases.

Relative Changes Don’t Tell the Whole Story

While the percentage of all enrollees that were children increased only a small amount, the absolute number increased dramatically. Of the 1.3 million total increase, nearly 1 million were in the Children’s program.  

Because Children’s Medicaid is such a large part of the overall Medicaid program, it’s hard to see changes in other program groups in the graph. If we zoom in to look at just the other programs, we see that Parents increased by about 84,000 people from a starting point of 123,000 – an increase of 68%. And Pregnant Women increased by about 250,000 people from a starting point of 136,000 – an increase of 184%.

How Much of the Increase Will be Deemed Ineligible Once Redeterminations Resume?  

We don’t know exactly. Some complicating factors are that eligibility rules for the two groups with the largest increases were changed by HB 133 (87-R), and HB 2658 (87-R).  Under these laws, children will receive six months of continuous coverage, with reduced eligibility checks for the remainder of the year; and eligibility was extended for pregnant women from 2 months postpartum to 6 months, with additional services provided by the Healthy Texas Women program following that.  

However, while we don’t know for sure, the Texas Health and Human Services Commission (HHSC) has recently released estimates for winding down continuous enrollment.  

The Texas Association of Health plans has estimated that 3.7 million Texans would need to have eligibility redetermined at the end of the public health emergency. As of December 2021, HHSC estimated that around 2.97 million enrollees who have been extended due to the public health emergency will need to have their eligibility redetermined.

HHSC’s plan is to reinstate eligibility redeterminations in three phases.  First are the estimated 880,000 individuals that HHSC believes most likely to be ineligible or transitioned from Medicaid to the Children’s Health Insurance Program.  A second, smaller group, of about 280,000 includes individuals likely to transition to other Medicaid eligibility groups. The final group of about 1.8 Million comprises individuals from the previous cohorts who still await determination.  

How Can Ineligible Individuals Get Health Coverage?

Given what we think we know about the population that is likely to lose Medicaid eligibility, it is highly likely that many would become eligible for a special enrollment period on the ACA’s individual marketplace.  However, depending on income, those special enrollment periods don’t last forever.  In many cases, the special enrollment period only lasts for 60 days following termination of prior coverage.  

Accordingly, as HHSC continues to plan its communications strategy during eligibility redeterminations, it should strongly consider including information to disenrolled individuals about their other coverage options, similar to what employers send to employees on termination of employment, and to what HB 133 (87R) began requiring to be sent to certain enrollees of the Healthy Texas Women program: 

Sec. 32.156. INFORMATION ABOUT AVAILABILITY OF SUBSIDIZED HEALTH INSURANCE COVERAGE. (a) The commission and each managed care organization participating in the Healthy Texas Women program shall provide a written notice containing information about eligibility requirements for and enrollment in a health benefit plan for which an enrollee receives a premium subsidy under the Patient Protection and Affordable Care Act (Pub. L. No. 111-148)

In addition, there are other common-sense steps that HHSC could take to minimize the disruption of this process to individuals who should retain eligibility.  These steps, and others were outlined in a 10 organization stakeholder letter to HHSC.  Some highlights include:

  • Utilizing available third-party data sources to flag address changes of current enrollees, including the US Postal Service National Change of Address database, and data from Managed Care Organizations (MCOs);
  • Leverage reliable third-party data sources to improve the efficiency of renewals;
  • Align renewals with other household members and other programs, and utilizing Supplemental Nutrition Assistance Program (SNAP) data where possible to enable administrative renewals (primarily for children).
  • Utilizing text messaging to directly contact impacted enrollees, and maximizing the ability of MCOs to do the same. 

Despite the increase in the number of residents covered by Medicaid during the course of the pandemic, Texas continues to have the highest number of uninsured residents in the country.  How the state addresses this Medicaid transition, including how the recommendations above are utilized, may impact how our state progresses on this key metric of financial protection.