A thoughtful approach to the end of the public health emergency will mitigate coverage lapses

Updated 7/18/2022: The declaration of the COVID-19 public health emergency was renewed on July 15

Since the beginning of the COVID-19 pandemic, the provisions of the national public health emergency have kept the vast majority of Oklahomans who are covered by Medicaid from losing that coverage. As the end of the public health emergency approaches (which could be as soon as mid-July 2022), the Oklahoma Health Care Authority (OHCA) has taken several steps to help eligible enrollees maintain coverage when the public health emergency ends. Many of Oklahoma’s outdated electronic data systems make more streamlined renewals impossible, and the state should commit to updating and improving those systems in the future.

The public health emergency kept Oklahomans insured during the COVID-19 pandemic

Oklahomans insured by Medicaid received streamlined and consistent access to care throughout the COVID-19 pandemic because of the provisions of the federal public health emergency. The U.S. Department of Health and Human Services declared a public health emergency on January 31, 2020, and it remains in effect today. It was extended in April 2022, and it could end in July of this year. In exchange for enhanced federal matching funds during the emergency, states (including Oklahoma) have been required to provide continuous coverage to most Medicaid enrollees, which has kept the uninsured rate from increasing during the pandemic. 

Since January 2020, Medicaid enrollment has increased in Oklahoma due to both the public health emergency and the implementation of Medicaid expansion. Continuous coverage – as provided by the public health emergency – mitigates coverage fluctuations, which in turn reduces barriers to care as well as administrative costs. 

200,000 Oklahomans could lose coverage when the public health emergency ends

Without proper preparation, the impending end of the federal public health emergency could be devastating for some enrollees and cause providers financial harm. OHCA estimates that 17 percent of Oklahoma’s 1.2 million Medicaid enrollees — or about 200,000 people — will lose coverage as OHCA will have to resume conducting annual eligibility reviews. 

This coverage loss could occur for several reasons. Some enrollees may simply be determined ineligible for Medicaid due to increases in income, in which case many will likely qualify for marketplace coverage. Individuals in this situation will have 60 days to apply for that coverage. Other enrollees may continue to be eligible for Medicaid but lose coverage because of procedural barriers. For example, because enrollees have not had to renew their coverage in more than two years, many have likely moved and forgotten to update their contact information. This would mean they may not receive renewal notices. Similarly, some enrollees — especially new enrollees, such as the Medicaid expansion group — may be unfamiliar with the renewal process and fail to return the necessary paperwork. In these instances, individuals and families may lose life-saving health coverage even though they remain eligible.  

OHCA has taken steps to mitigate coverage loss by building on federal requirements. Updates to data systems would help even more

The federal government will require state Medicaid agencies to take several actions to prepare for the end of the public health emergency. First, states may begin conducting renewals 60 days before the public health emergency ends. All renewals must be completed within 12 months of the end of the public health emergency. These renewals must use up-to-date information, and enrollees cannot be disenrolled based on old information. Coverage cannot officially end until the last day of the month in which the public health emergency ends. This means if the public health emergency ends in mid-July, coverage can end for enrollees determined ineligible as soon as July 31, 2022. Finally, states must report renewal data to the federal government to help identify compliance issues and “erroneous disenrollments.” The federal government has also recommended that states decrease administrative burden by spacing out renewals and take a “risk-based approach” to renewals by prioritizing individuals who are more likely to be no longer eligible. 

These federal expectations should be considered as the baseline, but OHCA has taken it a few steps further by outlining specific communications steps, using social media and television advertisements to raise awareness, and creating an informational toolkit for community partners who work with people eligible for Medicaid coverage. The toolkit includes information on communications strategies — using both email and text messaging — and resources for enrollees who may lose coverage, including highlighting enrollment navigators at MyOKPlan and assisters at Tulsa Responds. Finally, OHCA has committed to disenrolling ineligible members in a phased, risk-based approach, but the agency should consider publicizing those phases to help community organizations identify areas of greatest need. 

Several other options for streamlining renewals require large changes to state data systems. While these actions are unlikely to be available if the public health emergency ends in July 2022, OHCA should implement these strategies to make Medicaid coverage more accessible in the future:  

These actions will supplement the federal requirements and ensure that eligible Oklahomans retain their Medicaid coverage. 

Thoughtful, targeted state action will keep Oklahomans insured

The public health emergency was vital to keeping thousands of Oklahomans insured and healthy throughout the pandemic. As we approach the end of the public health emergency, policymakers must remain mindful that some 200,000 Oklahomans could lose health insurance. Coordination between OHCA and community organizations will ensure that fewer Oklahomans lose Medicaid coverage unnecessarily. It could also help connect Oklahomans with other forms of life-saving coverage if their qualifying circumstances have changed. Through thoughtful planning, Oklahoma can mitigate potential coverage gaps, which in turn will keep Oklahoma families healthier, strengthen the state’s workforce, and help maintain provider stability across the state. 


Emma Morris worked as Oklahoma Policy Institute's Health Care and Fiscal Policy Analyst from April 2021 to January 2024. She had previously worked as an OK Policy intern and as the Health Care Policy Fellow. Previous experience included working as a case manager with justice-involved individuals and volunteering as a mentor for youth in her community. Emma holds dual bachelor’s degrees in Women’s and Gender Studies and Public and Nonprofit Administration from the University of Oklahoma, and is currently working on a Master of Public Administration degree from OU-Tulsa. She is an alumna of OK Policy’s 2019 Summer Policy Institute and The Mine, a social entrepreneurship fellowship.

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