The ongoing COVID-19 pandemic has now spanned three years. A lot has changed and will continue to change once society and every industry, especially health care, adjusts to the new post-COVID world. With the pandemic, a federal public health emergency (PHE) was declared, and legislation was then passed that had a major impact on how health care is administered from both an operational and financial perspective. Many temporary provisions were put into place that mostly impact Medicaid but ultimately affect all health insurance payers. As we look ahead to a point at which the PHE ends, those temporary provisions start to end in what many in the industry are calling the “unwinding of the PHE.” This article aims to provide an overview of the flexibilities that have been offered as a result of legislation tied to the PHE, examine the impacts of increased Medicaid enrollment, and assess how the risk profile of covered lives for all health insurance payers has changed.
The PHE that has been in effect because of the virus SARS-CoV-2 (which causes the disease COVID-19, or simply COVID), was declared on March 12, 2020, retroactively effective as of Jan. 31, 2020.
Where does this leave us now? At the time of this writing, the PHE is under its ninth renewal (90-day extensions) and is set to expire July 15, 2022. HHS has previously informed states that at least 60 days’ notice will be provided, which means the end of the PHE will occur July 2022 or later. States receive the additional FMAP bump through the end of the quarter in which the PHE ends, which is slated to be Sept. 30, 2022. Before the omicron wave, many thought the PHE would end in early 2022. Popular opinion seems to have shifted to a later time period, with mid-to-late 2022 being the likely end of the PHE. Any continued uncertainty with the pandemic, such as another wave of cases, is likely to extend the PHE.
As we get close to the end of the PHE though, the focus shifts from case counts and test kits to the virus becoming endemic and moving past the PHE. This puts, front and center, the unwinding of all of the operational and financial elements that have been tied to the PHE since FFCRA was passed. When the unwinding starts, it will radically change the risk profile of Medicaid and all other health payors. Measuring and mitigating against this changing risk profile is where the nature of our profession as actuaries becomes critical. The biggest driver in the changing risk profile is the enrollment growth that has occurred with Medicaid since the pandemic began, as a number of these new members are at risk of losing their coverage.
Author(s): Colby Schaeffer
Publication Date: May/June 2022
Publication Site: Contingencies