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The COVID-19 Public Health Emergency Is Ending – What This Means For I/DD Providers and Consumers Receiving Medicaid

***10/13/22 UPDATE:  The Public Health Emergency (PHE) was extended.  The new deadline is now 1/11/23.***

***7/15/22 UPDATE:  The Public Health Emergency (PHE) was extended.  The new deadline is now 10/13/22.***

***4/16/22 UPDATE:  The Public Health Emergency (PHE) was extended.  The new deadline is now 7/15/22.***

The last two years of the Public Health Emergency (PHE) has created a holding pattern for benefits.  A federal order directed that those enrolled in Medicaid could not lose coverage during the pandemic.  No one could be dropped and no evaluations were made:  benefits were not at risk.

The PHE is due to expire on April 16, 2022 and for the first time in two years, there is a potential that it will not be renewed again by the US Department of Health & Human Services (HHS).  HHS has said that it will give states a 60-day notice, meaning if the PHE ends in April, coverage as within the PHE will extend thru June.

With the end of the PHE, Medicaid will resume its normal order of operations.  The Biden Administration and state officials are preparing for what is being called a “great unwinding”, as millions of people may lose their Medicaid benefits.

According to the Centers for Medicare and Medicaid Services (CMS), during the last two years, Medicaid enrollment has grown to a record high of 76.7 million people, up from 64.6 million in 2019.  That’s an increase of 15% or 12.1 million people.  As the PHE comes to a close, Medicaid will get back to its job of reevaluating each person’s eligibility, this includes your consumers.

Typically, renewal/redetermination notices and documents are processed by state Medicaid agencies but many are short staffed.  The Biden Administration has given states a year to move thru this process but officials say financial pressures will push them to go faster.

In March, CMS issued new guidance to state health officials on initiating eligibility renewals for all individuals enrolled in Medicaid upon termination of the PHE.  In this notice, CMS notes that it intends to promote the continuity of coverage for individuals and ease the burden on states by putting into place an orderly process.  The new guidance updates previous requirements for states and provides more flexibility. Now, states have a 12-month period from the end of the PHE to initiate actions to determine individuals’ eligibility.  CMS released this “unwinding” toolkit –

As a provider and representative-payee, you need to be prepared.

  • Make sure to get redetermination documents. You may need to create an outreach to consumers’ family or guardian who may receive the redetermination notice and documents.  Deal with the redetermination as quickly as possible.  Don’t rely on the 12-month extension.


  • The “unwinding” toolkit contains items you can use within your communications, such as copy and templates for mail, email and articles. There are also tips and graphics to use in your social media.  The key messaging is getting the necessary documents to ensure the renewal/redetermination gets processed.  Basically, helping to ensure your consumer’s benefits don’t fall through the cracks.


  • Make sure your consumer assets (typically checking accounts) fall below the $2,000 resource limit to maintain eligibility for benefits. Over the last two years, most consumers received three stimulus payments, totaling $3,200.  This, alongside consumers’ inability to get out and spend money has many checking accounts brimming over the resource limit.


  • If your consumers have excess funds over the resource limit, there is no need to perform a frivolous spenddown. This money can be saved and used by the individual as needed over their lifetime.  Excess funds can be put into an exempt resource as this money does not count against the $2,000 threshold.  The best exempt resource for a provider to use is its own special needs pooled trust (SNPT).


A SNPT brings many advantages to both consumer and provider.  When a consumer places their excess funds into a trust, they can then save any amount of money and still ensure their benefits.  This helps to enhance lives and improve outcomes.

A SNPT puts the power into a provider’s hand.  It is a total business-to-business solution for administration, compliancy and reporting.  It will support the entire community and can help to offset capital intensity for individuals in your care.  It’s a transparent tool used by executives, fiscal teams, DSP’s, family members and the individual, who can all interact with the trust account.

Arlington Heritage Group has made it easy (and quick) for providers to create their own special needs pooled trust.  We also provide all the day-to-day support to run the SNPT.  This is all offered to the provider at no cost and there is a low cost structure for consumers.

Arlington Heritage Group is a trust administrator and has been working exclusively with human service providers for over 30 years. Over 100 non-profits have made our special needs pooled trust their choice.  When we work together, we safeguard benefits and build resources for your community.