Loss of Medicaid Eligibility Increases HIPAA Special Enrollment Requests

1.5 minute read

Starting April 1, 2023, states that maintained continuous Medicaid enrollment during the COVID-19 pandemic can start terminating coverage for those individuals who are no longer eligible. As individuals lose eligibility for Medicaid coverage, employers may see an increase in midyear enrollment requests.

Continuous Enrollment for Medicaid

To receive additional funding, some states maintained continuous enrollment for individuals enrolled in Medicaid during the pandemic, despite any changes in eligibility status. The continuous enrollment requirement will end on March 31, 2023. Many individuals who lose Medicaid eligibility will enroll in subsidized coverage through the Exchange. It’s estimated that five million people will seek coverage under employer-sponsored health plans.

HIPAA Special Enrollment

The Health Insurance Portability and Accountability Act (HIPAA) requires group health plans to provide special enrollment opportunities in certain situations, including when employees and dependents lose eligibility for Medicaid coverage. Employees usually have 60 days to request special enrollment, but the deadline was extended during the COVID-19 outbreak period until July 10, 2023.

Employees and dependents who lose their Medicaid eligibility should be allowed to enroll in their group health coverage as special enrollees, assuming they are eligible under the plan’s terms, and they request timely enrollment. Download the bulletin for more details.

This blog is intended to be a compilation of information and resources pulled from federal, state, and local agencies. This is not intended to be legal advice. For up to the minute information and guidance on COVID-19, please follow the guidelines of the Centers for Disease Control and Prevention (CDC) and your local health organizations.