Due to pandemic-related continuous enrollment provisions, Medicaid rosters surged to over 90 million enrollees. On April 1, for the first time in 3 years, states will begin unwinding those provisions and disenrolling individuals no longer eligible for the program.

While a majority of states have taken numerous steps to prevent those still eligible for coverage from losing it for procedural reasons — such as renewal letters being sent to a wrong address — experts and lawmakers who spoke on panels at America’s Health Insurance Plans 2023 Medicare, Medicaid, Duals & Commercial Markets Forum on Thursday remain concerned.

Arkansas state representative Deborah Ferguson (D-51), who is a dentist, said her biggest concern is for people with chronic conditions who “go from Medicaid to employer insurance or Affordable Care Act insurance … are they going to have to get another prior authorization for treatment, are they going to have to get another prior authorization for medicine, is the formulary going to be different … Are they going to have this huge gap in care that’s really going to create problems?”

Typically, Medicaid processes renewals on an annual basis. Due to provisions in the Families First Coronavirus Response Act and the Coronavirus Aid, Relief, and Economic Security Act, states were required to maintain continuous enrollment for all Medicaid enrollees until the end of the public health emergency (PHE) and in return were granted a 6.2-percentage point bump in their Federal Medical Assistance Percentage. (For each dollar the state spends on Medicaid, the federal government provides a match rate that changes year to year.)

As a result of these provisions, Medicaid and the Children’s Health Insurance Program (CHIP) will have increased by 30% or 23.3 million people by March 31, according to estimates from the Kaiser Family Foundation (KFF).

Beginning on April 1, all 92 million enrollees will be up for renewal and the increased federal assistance will go away.

This change comes as a result of a provision in the Consolidated Appropriations Act, passed in December 2022, which decoupled the continuous enrollment provision from the PHE, and named March 31 as the end of the continuous enrollment period.