During the Public Health Emergency (PHE), the State of Wisconsin was required to keep people enrolled in Medicaid as a condition of receiving a temporary increase in the federal share of Medicaid costs. When the PHE ends (recently extended to January of 2022) so will the increased funding, and the state will need to look at whether currently eligible individuals will be renewed for benefits.
Those individuals who could keep benefits during the PHE were:
- Individuals who did not pay their patient liability or monthly cost share;
- Individuals who did not report changes in assets, income, work status or household composition;
- Individuals who received maximum FoodShare benefits during the pandemic regardless of qualification; and
- Individuals over age 65 who received prescription drug benefits but did not do their annual renewals or pay the annual fee.
When the enhanced federal funding ends, states will need to resume processing renewals for eligibility, many of which have been pending for almost 18 months. Current federal guidance provides that states will have up to 12 months to discontinue benefits that were extended under the PHE. Further, an individual must be provided with at least 60 days advanced notice before losing benefits.
For individuals who properly reported the receipt of excess assets and income during the PHE and continued to receive benefits, an overpayment occurred that has not yet impacted benefits. For those who did not properly report changes in resources, a discontinuance of benefits may be looming. The fate of those who properly reported changes remains to be seen in terms of how the penalty for overpayment will be treated. Generally, only those overpayments that are due to a consumer’s failure to report or provide updated information are recoverable. Consult with your attorney to ensure that you are provided with the requisite time frame to provide necessary eligibility verification and proper notice of any adverse action regarding benefits.