COVID-19 Public Health Emergency and Continuous Coverage Unwinding – Medicaid Eligibility

The federal COVID-19 Public Health Emergency (PHE) implemented flexibilities that help people across the country get on, and stay on, Medicaid. As a result, Medicaid enrollment numbers swelled during the pandemic.

Originally, the flexibilities and protections put in place during the pandemic were going to end with the end of the federal COVID-19 public health emergency (PHE). However, Congress passed the Consolidated Appropriate Act of 2023, which set the end date for the pandemic related Medicaid continuous coverage requirement as March 31, 2023. This means that state Medicaid agencies will begin the process of redetermining Medicaid eligibility for those beneficiaries who have not had their coverage renewed during the PHE as early as February 1, 2023. Medicaid terminations will begin as early as April 1, 2023 and end 14 months after the process starts, but some states will work to do it more quickly. It is anticipated that millions of individuals and families could lose coverage through this unwinding process.

Public education, outreach and advocacy will be critical to ensuring that individuals and families do not erroneously lose coverage. NHeLP, our partners, and other organizations will be supporting advocates on the ground to ensure a smooth unwinding process that preserves Medicaid coverage for all people who remain eligible.


NHeLP’s litigation team is monitoring the continuous coverage unwinding and focusing on this litigation. If you are interested in discussing litigation, please contact NHeLP’s Litigation Director, Jane Perkins at [email protected].

PHE Unwinding Resources and Analysis

Meet the Legal and Policy Experts working on the PHE unwinding process

Miriam Delaney Heard
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Miriam Delaney Heard

Senior Attorney

Miriam Delaney Heard is a Senior Attorney in the National Health Law Program’s North Carolina office. In addition to…

Elizabeth Edwards
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Elizabeth Edwards

Senior Attorney

Elizabeth Edwards is a Senior Attorney in the National Health Law Program’s North Carolina offices. In addition to working…

Alicia Emanuel
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Alicia Emanuel

Senior Attorney

Area(s) of Expertise: California, Medi-Cal Eligibility, Covered California, Exchange Coverage, Children's Health, CA Children's Services Program  Alicia Emanuel is…

Sarah Grusin
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Sarah Grusin

Senior Attorney

Area(s) of Expertise: Due Process, Immigrant Access to Care, Algorithms and Computer Systems, 1115 Waivers, Court Access and Private…

Kimberly Lewis
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Kimberly Lewis

Managing Attorney - Los Angeles

Kimberly Lewis is the Managing Attorney of the National Health Law Program’s Los Angeles offices. Kim works on state…

Jane Perkins
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Jane Perkins

Legal Director

Jane Perkins is the National Health Law Program Legal Director. As such, she leads our efforts to ensure that…

Skyler Rosellini
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Skyler Rosellini

Senior Attorney

Skyler Rosellini is a Senior Attorney at the National Health Law Program’s Los Angeles office. Skyler’s work focuses on…

Mara Youdelman
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Mara Youdelman

Managing Attorney - Washington, DC

Mara Youdelman is Managing Attorney of the National Health Law Program’s Washington D.C. offices. Mara has worked at the…