- Under the FFCRA, New Jersey must maintain continuous enrollment of Medicaid beneficiaries through the last day of the month in which the PHE ends, among other conditions, in order to receive a temporary increase in Federal Medical Assistance. All states, including NJ, implemented this option. The public health emergency will likely end in the late spring/early summer of 2023.
Medicaid enrollment has increased by more than 20 percent since the beginning of the COVID-19 public health emergency (PHE). Growth in Medicaid enrollment is largely due to the requirement that NJ guarantee the continuous enrollment of applicants because of the Federal Families First Coronavirus Response Act (FFCRA).
When the PHE ends, NJ will be tasked with addressing a significant volume of pending renewals, redeterminations and other eligibility actions across Medicaid, CHIP and BHP. The volume of pending actions is expected to place a heavy burden on the state workforce and operations, and the state will need to take action to minimize the risk of inappropriate terminations of eligible individuals.
When the PHE ends, New Jersey will still be obligated to meet existing federal requirements for renewals, verifications, applications, and oversight of their programs. Compliance with these existing requirements will be critical to ensuring that timely and accurate eligibility determinations are completed and that eligible individuals remain enrolled or are transferred seamlessly to other coverage.
If New Jersey does not comply with federal requirements may be required to develop a corrective action plan (CAP). If at any point CMS determines that the state is not meeting the requirements outlined in an established CAP, CMS may initiate formal compliance proceedings and Federal Financial Participation may be at risk.
I will address the subject of Medicaid renewals and terminations in a series of blogs to follow.
To discuss your NJ Medicaid matter, please contact Fredrick P. Niemann, Esq. toll-free at (855) 376-5291 or email him at fniemann@hnlawfirm.com. Please ask us about our video conferencing or telephone consultations if you are unable to come to our office.
By Fredrick P. Niemann, Esq. of Hanlon Niemann & Wright, a Freehold Township, Monmouth County, NJ Medicaid Attorney