The Families First Coronavirus Response Act (FFCRA) was enacted on March 18th 2020, in response to the COVID-19 pandemic. It included provisions to help individuals maintain their Medicaid coverage without renewing their eligibility every few months. However, the FFCRA was only a temporary measure and did not provide permanent changes to Medicaid eligibility rules. This extension will end on March 31st 2023, affecting between 5 and 14 million people.

CMS has introduced a new Special Enrollment Period for people losing their extended Medicaid or CHIP benefits. It provides an opportunity to enroll in ACA Marketplace health insurance plans and ensures access to affordable and comprehensive healthcare coverage.

Marketplace-eligible consumers who lose Medicaid and CHIP coverage due to the Unwinding can qualify for the Unwinding SEP between March 31st 2023, and July 31st 2024, by submitting or updating an application.

What is the Unwinding Period?

The Unwinding Period is the process of resuming regular eligibility and enrollment operations after the continuous enrollment condition ends on March 31st 2023. It includes renewals and coverage terminations. States may begin terminating Medicaid enrollment for individuals no longer eligible as early as April 1st 2023.

  • States will have:
    • States will have up to 12 months (i.e., March 31, 2024) to initiate renewals for all individuals enrolled as of
      the last day of the continuous enrollment condition.
    • States will have up to 14 months (i.e., May 31, 2024) to complete an eligibility renewal for all individuals in
      their programs.
  • Renewals have begun on February 1, with the first terminations effective on 1st April 2023.
  • Consumers who receive advance notice that their Medicaid is ending on March 31st can start enrolling immediately in other coverage to ensure continuity of coverage. 

  • Consumers do not have to answer any new application questions to be eligible for the Unwinding SEP.  The existing application question on has been updated by CMS to ask about recent loss of Medicaid or CHIP coverage, and the functionality has been updated to grant the Unwinding SEP to eligible consumers. Eligibility can also be determined through partner applications that ask about recent loss of Medicaid or CHIP coverage

  • Consumers are not required to provide documentation to prove their eligibility for the Unwinding SEP. They will need to attest to the loss of Medicaid or CHIP coverage as a part of the application process.

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The Unwinding Period Timeline

Consumers who lose Medicaid or CHIP coverage from March 31st 2023, through July 31st 2024, will qualify for a 60-day Special Enrollment Period (SEP) starting from the day they update or submit a Marketplace application. The Unwinding SEP will be automatically granted to consumers based on their applications.

Consumers who declare that they have previously lost Medicaid or CHIP coverage, their Marketplace coverage will commence from the first day of the month after they choose a plan. For instance, if a consumer picks a plan on August 25th, coverage will start from September 1st.

Consumers who indicate that they will lose Medicaid or CHIP coverage in the future, their Marketplace coverage will commence from the first day of the month following their last day of Medicaid coverage

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