Coronavirus (COVID-19) - UNWIND Phase

On January 30, 2023, the Biden Administration announced its intent to end the national emergency and public health emergency declarations on May 11, 2023, related to the COVID-19 pandemic. These emergency declarations have been in place since early 2020 and gave the federal government flexibility to waive or modify certain requirements in a range of areas, including in the Medicare, Medicaid, and CHIP programs. In addition, Congress also enacted legislation—including the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security (CARES) Act , the American Rescue Plan Act (ARPA), the Inflation Reduction Act (IRA), and the Consolidated Appropriations Act, 2023 (CAA) that provided additional flexibilities tied to one or more of these emergency declarations, and as such they too are scheduled to expire when (or at a specified time after) the emergency period(s) expires.

On January 5, 2023, CMS issued an informational bulletin on the provisions included in the Consolidated Appropriations Act, 2023 (CAA, 2023) related to the Medicaid continuous enrollment condition. The CAA, 2023 updates various Medicaid and CHIP provisions, including significant changes to the continuous enrollment condition of the Families First Coronavirus Response Act. Under the CAA, 2023, expiration of the continuous enrollment condition will no longer be linked to the public health emergency (PHE) and instead the condition will end on March 31, 2023. Following the end of the condition, states will have up to 12 months to initiate, and 14 months to complete, a renewal for all individuals enrolled in Medicaid, the Children's Health Insurance Program, and the Basic Health Program.

CMS has “released information on a temporary Exceptional Circumstances Special Enrollment Period (SEP) for consumers losing Medicaid or CHIP coverage due to unwinding of the Medicaid continuous enrollment condition. From March 31, 2023, and lasting through July 31, 2024, the Marketplaces using the Federal platform will be providing additional flexibility for Marketplace-eligible consumers losing Medicaid or CHIP to enroll in Marketplace coverage during and immediately following the end of the Medicaid Continuous Enrollment Condition unwinding period. This flexibility will be provided by facilitating access on HealthCare.gov to an SEP, referred to as the “Unwinding SEP.”

The guidance is available at https://www.cms.gov/technical-assistance-resources/temp-sep-unwinding-faq.pdf.

MDHHS COVID-19 UNWIND

MDHHS has issued many COVID-19 response Medicaid policy bulletins and L letters which changed existing policy and processes under the guidance of the federal PHE. Providers will see an increase in updated COVID-19 response policy bulletins and L letters to accommodate the end of the PHE. Refer to the PHE policy crosswalk table below to see current and upcoming policy changes. 

State of Michigan Guidance and Resources

The State of Michigan provides updates on the disease's spread within the state, as well as frequently asked questions available here.

MDHHS COVID-19 Vaccine information can be located here.

Behavioral Health and Developmental Disabilities Administration (BHDDA) posts communications related to COVID-19 policy updates and changes which impact the public behavioral health system.