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Update on Dual Recertification and Covid: PHE Extension

We’ve written before about the Public Health Emergency and its impact on Medicaid recertifications. With Secretary of Health and Human Services Alex Azar announcing an extension of the PHE on Friday, we thought it was worth re-visiting.

As with so much else in the time of Covid-19, state Medicaid administrations have faced unique challenges as they navigate the impacts of the pandemic. Under the rules of Public Health Emergency declared by Secretary of Health and Human Service Alex Azar, state Medicaid administrations that accept increased federal funds must adhere to Maintenance of Effort (MOE) requirements. One of these requirements is that states cannot disenroll any Medicaid recipient who was enrolled as of March 18th for any reason except for an out-of-state move or voluntary termination. Of note, the law does not require states to suspend renewals or periodic reviews.

As the PHE has progressed, more and more states have announced a resumption of Medicaid recertification processes. States that have recently re-started their Medicaid recertifications include Arizona, Florida, North Carolina, Ohio and Texas. These states have joined the many states that never paused their recertifications in keeping the administrative processes moving forward while holding any disenrollments in abeyance. This creates an interesting challenge for DSNPs and Medicare Advantage plans with Dual Medicare/Medicaid enrollment. While most of these plans have a program in place to help members retain their crucial Medicaid benefits, navigating the MOE requirements requires thoughtful planning.

At BeneLynk we are advising our clients with members in any state with ongoing Medicaid recertification to continue to provide assistance to these members. By staying current with this population, MA and DSNP plans avoid a costly gap in Medicaid coverage for their members. On the other hand, in states where the Medicaid renewals are postponed, we are recommending a pivot in communication, focusing on how we can help members address any short or long term SDoH barriers. We believe the most important role we can play is to serve as informed experts to our clients, helping to craft a state-specific strategy based on the values and goals of our clients.

As always, we are excited to talk about our Medicaid recertification program or Social Determinants of Health in general. If you want to chat, please drop us a note today at

About the Author

Sean Libby has been an advocate for seniors, people with disabilities, veterans, and individuals with low income for over 18 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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