Colorado officials are preparing to review the Medicaid eligibility of more than half a million residents in an effort unprecedented since the implementation of the Affordable Care Act as the federal response to the COVID-19 pandemic begins to unwind.

At the beginning of the pandemic, the federal government declared a public health emergency. In exchange for additional funding, Colorado — and the rest of the United States — has generally not been reviewing or removing people who no longer qualify for Medicaid and still live in the state.

Anyone who’s enrolled in Medicaid at some point in the past two years has stayed there, unless they’ve moved, died or voluntarily withdrawn. But when the public health emergency ends, the funding will stop, and states will need to “unwind” from it: reviewing their Medicaid rolls for who should and shouldn’t continue to receive the service.

Some share of 561,000 Coloradans — roughly 26% of the entire Medicaid population here — may fall into that category, Marivel Klueckman, the state’s Medicaid eligibility division director, said last week. Not all of them are ineligible, she added, but that’s how many the state has identified since March 2020 as potentially no longer qualifying, for reasons like higher income.

Every single one of those roughly 561,000 people will need to be reviewed, Klueckman said, to determine who still needs to be enrolled and who should be moved off. According to Kaiser Health News, 30% of those in that group is at risk because they haven’t responded to state requests, and 40% based on their income levels.

But there’s no way right now to know just what that number will be, state officials said. The public health emergency is technically slated to end in April, but it will almost certainly be extended: The federal government has told states that they will receive 60 days’ notice before it ends, and that notice has not come.

When it will, though, is a very expensive question, officials said. Once it does, states will essentially have 14 months to clear their rolls, but the funding enhancement will end once the emergency does. Tracy Johnson, Colorado’s Medicaid director, said the state has budgeted for the transition.

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The Medicaid program is partnering with Connect for Health Colorado, which runs the state’s health insurance exchanges, to transition ineligible people from Medicaid to the exchange. Many of those who aren’t eligible for Medicaid will likely still qualify for substantial assistance through Connect for Health.

If that transition — and the unwind in general — goes well, the state’s uninsured rate should hold steady or improve, Johnson said. If it doesn’t, Colorado could see its uninsured rate increase for the first time in a decade.

“And I don’t want that to happen,” Johnson said.

The state will review as much data as it has for those people — any information from the Supplemental Nutrition Assistance Program, for instance, or cash assistance — to make it a “passive renewal,” she said: If a person has recent income filings on hand for SNAP, for instance, and those show that person still qualifies for Medicaid, then they’re set.

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If the state doesn’t have that information, she continued, then those people have to work through the renewal process. She urged Coloradans who are on Medicaid to ensure their addresses are updated and current, so the correct information and enrollment information can find them. Enrollees should also reply to any messages they receive from the state, officials said.

The unwind will happen in phases, officials said, rather than every person being reviewed and potentially removed at once. 

Losing Medicaid qualifies for special enrollment in the exchanges via Connect for Health Colorado. Monica Caballeros, spokeswoman for the program, said Connect for Health would use social media, direct emails and its team of on-the-ground brokers and “assisters” to transition people from Medicaid to the exchanges.