In this letter to Department of Health and Human Services Secretary Alex Azar, MACPAC looks ahead to the end of the COVID-19 public health emergency (PHE), requesting that the Secretary give state Medicaid programs sufficient advance notice as to when the PHE will end, and early and clear guidance on requirements for returning to normal operations for states well in advance of actions that would terminate Medicaid flexibilities. These steps would help ensure a transition out of the public health emergency that minimizes disruption for Medicaid beneficiaries, providers, plans, and states.
The letter describes how the Commission expects the end of the PHE to affect Medicaid operations as well as the time states will need to develop state plan amendments that extend beyond the PHE. The Commission also observes that economic effects of the pandemic—declining state revenues and increasing enrollment—will likely to continue challenging state Medicaid programs even after the official public health emergency ends.