Preparing for Alabama’s Medicaid Unwinding Process

By: Alli Swann and Kelli C. Fleming, Esq. – Burr & Forman LLP

Over the past three years, Medicaid recipients have benefitted from uninterrupted coverage, contributing to one of the lowest periods of U.S. uninsurance. However, with the public health emergency’s (“PHE”) end reintroducing traditional Medicaid redetermination plans, Alabama providers should prepare for a potential spike in uninsured patients.

In 2020, Congress passed the Families First Coronavirus Response Act (FFCRA), which sought to bolster health insurance access during the PHE. To accomplish this goal, Congress provided increased federal funding for states to activate measures focused on maintaining access to health coverage. The package offered states additional federal funding in exchange for ensuring that low-income individuals would retain their health coverage during the pandemic. States had to meet several conditions to obtain federal funds, including a continuous coverage requirement. Under the continuous coverage requirement, Medicaid enrollees could not lose eligibility unless they requested in writing to be removed, moved out of state, or died. Continuous coverage eligibility also protected an enrollee’s coverage despite income or family size changes.

Medicaid enrollments rose substantially in response to the continuous coverage requirement. Nationally, Medicaid enrollment rose from approximately 64 million in February 2020 to 86 million by February 2023. In Alabama, approximately 800,000 people were on the Medicaid roll before the PHE’s onset. This number increased to 1.2 million people during the pandemic. However, with this “unwinding” period underway, the Robert Wood Johnson Foundation and the Urban Institute estimate that approximately 61,000 Alabamians could lose Medicaid coverage by June 2024.

The Consolidated Appropriations Act, 2023, separated the continuous enrollment condition from the PHE, ending the continuous enrollment provision on March 31, 2023. On April 1, Alabama resumed verifying eligibility information for current enrollees and slowly dis-enrolling individuals based on income or household size changes.

So, what does the Medicaid unwinding process mean for providers? 

Reducing the information gap is a critical first step in mitigating coverage loss. Medicaid providers should prepare to advise patients about the unwinding process and counsel those who have lost Medicaid coverage. 

Alabama Medicaid’s Partner Toolkit outlines important steps providers should take when talking with patients who are Medicaid recipients:

• First, providers should ask the patient to verify their contact information with Medicaid. Providers should emphasize the importance of ensuring up-to-date information. 
• Second, providers should ask the patient if they received a letter about their coverage from Medicaid. If so, providers should advise their patients to complete and return the included form to Medicaid, as failure to do so could result in termination.
• Finally, providers should be prepared to advise their patients on other health coverage options if they no longer qualify for Medicaid.

Dr. Shawn Cecil, MD, Pediatrician and Assistant Professor at the University of Alabama Medical Center and College of Community Health Sciences, emphasized the importance of offices verbally communicating with patients, encouraging them to update their contact information with Medicaid. Dr. Cecil also recommends that offices train a Medicaid Application Assister to help patients complete their online Medicaid application, which helps lead to a quick turnaround time for redetermination results.

With Alabama’s uninsured population anticipated to rise, Dr. Cecil advises that physicians prepare for a change in the types of medical care patients will seek. “Studies have shown that patients without health insurance have more preventable visits to the Emergency Room compared to those with health insurance. Higher levels of ER utilization leads to higher costs and can also lead to delayed medical treatment for those with serious needs.”

As the Medicaid unwinding process continues in Alabama, providers can stay up-to-date on Alabama Medicaid’s  Alerts Webpage.

 Kelli Fleming is a Partner at Burr & Forman LLP and practices exclusively in the firm’s Healthcare Practice Group. Kelli may be reached at (205) 458-5429 or kfleming@burr.com.

Alli Swann is a law student at the University of Alabama School of Law.