The Great Unwinding

It’s hard to believe that we are still under a national public health emergency because of the COVID-19 pandemic, but many are predicting that will finally come to an end later this year. From the perspective of the Centers for Medicare and Medicaid Services (CMS), this is what they are referring to as the “Great Unwinding.”

The Great Unwinding is how CMS refers to the undoing of several health coverage requirements that were implemented by legislation, regulation, and executive order because of COVID-19. Amongst many healthcare and coverage provisions that were implemented over the past 2.5 years, the following provisions are particularly noteworthy:

• Medicaid eligibility was expanded. States have been required to provide continuous eligibility for Medicaid to anyone who was enrolled in coverage as of March 18, 2020.
• Advanced Premium Tax Credits (APTCs) on Marketplaces were increased, and eligibility for APTCs expanded to additional individuals.
• Extensions to elect COBRA coverage and make COBRA premium payments have been provided. Extensions to make a special enrollment election for group coverage has also been provided.
• Cost-sharing for COVID-19 vaccines and testing was eliminated in many circumstances.
• Telemedicine coverage was expanded for Medicare, Medicaid, and CHIP beneficiaries.

These provisions expire when the national public health emergency is declared over, or by the end of 2022 as it relates to the changes to APTCs. The so-called Great Unwinding is expected to cause anywhere between 8-15 million people to lose coverage. Additionally, there is an expectation that some individuals may forgo certain medical care as some of the coverage provisions expire.

The national public health emergency is set to expire on July 15, 2022, but it is likely to be extended beyond that date. The Biden administration has told states that it would provide them with at least 60 days’ notice of the end to the national public health emergency. Congress could also act to extend some of the provisions and/or make them permanent. The Great Unwinding could be a topic of debate in the upcoming November elections.