Medicaid Expansion Ends: Tips for Employers Impacted by Medicaid Redeterminations and Unwinding

Date: May 16, 2023

The end of the pandemic-era Medicaid expansion is fast approaching, and it will have implications for businesses that offer employer-sponsored health plans.

During the pandemic, Medicaid redetermination, the process states use to confirm people qualify for Medicaid, was put on hold. Now that the public health emergency has ended, states have started to check Medicaid eligibility and update its rolls. This “unwinding” of pandemic rules means that some employees will lose Medicaid coverage.

Individuals who no longer qualify for Medicaid will need to consider other health insurance programs, including employer coverage if available. Businesses that offer health plans have certain communication requirements during this special open enrollment period.

Here are three steps employers can take to prepare for employees who lose Medicaid coverage:

  1. Communicate with employees: Employers should communicate with their employees about the upcoming changes and provide clear instructions on enrolling in their employer-sponsored health plan. Your health insurer or agent should be able to assist with necessary paperwork and notices. To ensure that those who remain eligible for Medicaid are enrolled, the federal government has released resources to assist states and employers. Employers can find more information here.
  2. Review your health plan options and ensure compliance with HIPAA regulations: Employers must comply with HIPAA regulations and provide a 60-day special enrollment period to employees who were previously covered under Medicaid. Employers must communicate the availability of the special enrollment period and the steps employees need to take to enroll in their employer-sponsored plan.
  3. Consider partnering with a benefits consultant: Employers may want to consider partnering with a benefits consultant to help navigate the changes related to Medicaid redetermination and the end of the public health emergency. A benefits consultant can provide guidance on compliance issues, plan design, and employee communication strategies.

The end of the pandemic-era Medicaid expansion will require employers who offer health care plans to take certain steps to ensure their employees who are eligible can enroll. Employers should be proactive in communicating with employees, familiarize themselves with available resources, and help employees navigate the enrollment process to avoid potential penalties. By taking these steps, employers can ensure that their employees have access to quality healthcare coverage.

Resources:  EBSA Flyer for Employees;  DOL Blog Post; FAQ Part 58 from CMS/CCIIOCMS website with additional materials

Employers with additional questions can reach out to NFIB at [email protected]


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