Much of the current discourse surrounding public funding of healthcare in the United States revolves around one issue: the present Public Health Emergency, or PHE.

When the pandemic hit the country in February of 2020, the United States government responded by expanding its efforts in terms of public health. Among these expansions were additions to available services covered by Medicare and Medicaid.

However, a majority of these changes occurred under the umbrella of the PHE — meaning that once the public health emergency was declared to be over, markets would have to contend with the resultant changes and reversions to previous practices.

To be clear, while many states have returned to something resembling their pre-COVID-19 behaviors, and an overwhelming majority of Americans have received a vaccination against COVID-19, hundreds of Americans still die of COVID-19 every day. Despite this, the growing sense that the pandemic is ‘over’ has led many to believe that the government-declared PHE will soon be declared to be ‘over’ as well.

As of the time of writing, this does not appear to be the case. While the PHE is currently set to expire in the middle of January, the Biden administration has indicated that they plan to give a notice of at least 60 days before the PHE ends. It is now less than 60 days until the current end date; therefore, it is same to assume that the PHE will be extended for at least another 90 days once its current deadline has been reached.

Nonetheless, a deadline is seemingly imminent, and once the deadline passes, the consequences cannot be understated.

For example, Medicaid and CHIP enrollment increased significantly across the first two years of the pandemic for numerous reasons. One of the reasons these enrollment numbers stayed high was a provision in the Families First Coronavirus Response Act (FFCRA) that required continuous coverage for Medicaid enrollees until the end of the month in which the PHE is concluded. This means that states could not disenroll people from coverage.

When the PHE ends, states can begin redeterminations. If a person is no longer eligible for Medicaid, or if they simply face issues when clarifying their Medicaid eligibility status, they can be kicked out of the program — an event that KFF estimates will result in between 5 million and 14 million people losing Medicaid coverage and becoming uninsured.

CMS is currently attempting to plan for this possible wave of newly-removed enrollees by requiring states to provide a plan through which they will handle the end of the PHE in terms of Medicaid enrollment.

Although states are encouraged to make their plans available and include the public in the discussions around them, there is no legal requirement for them to do so, nor must the plans be approved by CMS before being enacted. Additionally, there is no guarantee that those being removed from Medicaid will be informed about alternatives in the current healthcare marketplace.

Some states have already provided information about their plans to “unwind” Medicaid programs. For example, both Wisconsin and North Carolina have created brief guides for those concerned about the future of their Medicaid status, though, as many plans are not yet fully set, the available information is incomplete and subject to change.

One possible solution to some of these issues would be Medicaid expansion, something already done by 39 states and Washington, D.C. The potential of this expansion, too, is uncertain.

Medicaid expansion tends to fall along party lines, with Democrats being largely for it and Republicans, in contrast, against it. While many Republican-led states have still expanded Medicaid, all of the remaining 11 states without Medicaid expansion have legislatures controlled by Republicans, meaning that the future of Medicaid in these states is still an open question.

For now, the PHE is still in place, though it is now incumbent on the states to design plans to handle the consequences once it inevitably ends. We are monitoring the situation closely and will keep you updated as it develops.