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The End of the Public Health Emergency and Medicaid Retention Services…

How managed care organizations can prepare for the reinstitution of Medicaid recertification procedures.

As Bill Murray’s character in Groundhog Day might have said, “well they extended the Public Health Emergency…again.” On July 19th Secretary of Health and Human Services, Xavier Becarra issued another extension to the PHE. By my count this is the 6th renewal of the PHE. We have received informal guidance to expect the PHE to end as we turn the calendar to 2022. Health and Human Services has also put out the word that they intend to give 60 days’ notice when ending the PHE. Some back of the envelope math shows that the next (possible) extension in the middle of October could serve as that notice with the PHE expiring with the new year.

In any case, at some point the PHE must come to an end. When it does, there will inevitably be some turbulence. CMS has notified the states that they need to develop written plans for managing the end of the PHE and the move toward business as usual in Medicaid recertifications. Fortunately, most of the states are conducting recertifications on a regular schedule and simply holding any removal from Medicaid in abeyance. However, some states still have not re-started recertifications. Some of the states that have re-started, have altered the schedule so that a recertification date no longer aligns with the anniversary of when the member got benefits. And, as of now, there is no systematic way to know which members have failed to comply with the recertification process and are subject to removal after the end of the PHE. (On that last note, BeneLynk strongly supports an initiative for the states to provide this information to managed Medicaid, Medicare Advantage, DSNP, MMP, and other managed care plans with members who have Medicaid).

For now, managed care plans with Medicaid enrolled members need to develop a plan for helping the members keep their Medicaid benefits, and to assist those who have lost Medicaid enrollment for failure to complete the annual renewal process to get re-enrolled (ideally during the grace period when applicable). This necessitates a member engagement process that is highly customized. Members need to be given state-specific information and renewal options. Generic calls to action will be inadequate in what will inevitably be a confusing time for some members. Instead, all communications, including mailings and scripts, need to reflect the most recent information, and the specific options for recertification being offered by the relevant state Medicaid agency.

At BeneLynk, we are actively working with our clients to plan for the post-PHE world. This means understanding the specific state plans, developing targeted messaging with customized calls to action, and creating contingency plans based on future developments. Now, more than ever, it is important to build a human-to-human connection to give members the information they need from a person they trust. The information needs to be specific and accurate, but the medium of communication also matters. Plans will succeed post-pandemic based on their ability to deliver actionable information in an effective manner.

We’re always happy to talk about our approach, and to hear of any best practices in the industry. Drop us a line today to chat at

About the Author

Sean Libby has been an advocate for seniors, people with disabilities, veterans, and individuals with low income for over 19 years. At BeneLynk, we are committed to helping managed care plans to deliver superior Social Determinant of Health solutions to their members. We are always looking to learn more and would like to hear your ideas on how best to assist members in need. Drop us a note at

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