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Loss of Medicaid Eligibility Increases HIPAA Special Enrollment Requests

Loss of Medicaid Eligibility Will Increase 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.

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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.

National Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Readers are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the readers’ business activities.

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Steve Smith

Steve Smith

Steve Smith, Employee Benefits Consultant for National Insurance Services, has his energy level permanently set at “high.” His maxim is “work hard, play hard.” Steve’s an expert in getting groups of people working together for a higher cause. Minnesota schools, cities, and counties rely on Steve’s unique and creative ideas of engaging employees in their own health and wellness to lower utilization trends. He has 20+ years in the health insurance field doing compliance, cost mitigation, utilization, analytics, wellness plans, and strategic planning. Steve is a licensed insurance agent and holds the designations for Managed Healthcare Professional (The Health Insurance Association of America), Certified Patient Protection and Affordable Care Act Professional (National Association of Health Underwriters), and Group Benefits Disability Specialist (Hartford School of Insurance). He specializes in Employee Benefits Consulting for Minnesota schools, cities, and counties including fully insured, self-insured, and stop-loss plans.