The End of the Continuous Enrollment Period in Montana

Beginning in April 2023, the State of Montana, like other states, will begin a year-long period of “unwinding” Medicaid coverage. In response to the COVID pandemic, the 2020 Families First Coronavirus Response Act (FFCRA) increased federal Medicaid funding and prohibited Medicaid beneficiaries from being disenrolled during the COVID-19 Public Health Emergency (PHE). As a result, Medicaid enrollment in Montana grew by 30 percent (as of September 2022) and will continue to grow through March 2023. After that, based on recently passed federal legislation – the 2023 Consolidated Appropriations Act (CAA) – the moratorium on disenrollment will end. In April 2023, Montana will begin to redetermine the eligibility of all Medicaid beneficiaries, numbering more than 300,000 persons, and terminate coverage for those who no longer appear eligible. The new legislation provides some guardrails for the redetermination process and provides transitional federal funding from April to December 2023, which we estimate is worth about $30 million for Montana.

A new report by HPM doctoral student Isabel Platt and Prof. Leighton Ku, funded by the Montana Healthcare Foundation, discusses the background and provides an update on the Montana Department of Public Health and Human Services’ (DPHHS’) proposed plan to complete redeterminations and renewals within 12 months, by March 2024. Based on this timeframe, we estimate about 71,000 people will lose Medicaid coverage by January 2024, a 24 percent decline from March 2023 enrollment.

We suggest an alternative plan to conduct redeterminations at a slower pace that is still within federal guidelines. It includes a more gradual 14-month pace, more time for beneficiaries to respond to requests for renewal information prior to termination, and greater resources for outreach and referrals to other insurance coverage, especially the Health Insurance Marketplace. Under this alternative plan, we estimate that about 9,000 fewer Montanans would lose Medicaid coverage by May 2024.