AFS Special Procedures: Medicaid Guidance During COVID-19

Center for Medicaid/Medicare Services CMS has issued new guidance on maintaining medical benefits during the COVID-19 pandemic. As a result, Oklahoma Healthcare Authority has made system changes to maintain member eligibility throughout the State of Emergency, except for members who voluntarily want to terminate SoonerCare (Medicaid) or who have passed away.

Pursuant to the CARES Act, Medicaid would need to remain open. Therefore, OHS/DHS will adhere to the mandate by implementing the following directives:

Continuous Coverage

The continuous coverage requirement prohibits a State from terminating any individual who was enrolled on March 18, 2020, even if he or she ceases to be eligible for Medicaid (SoonerCare) during the public health emergency period, COVID-19. This is regardless of any changes in circumstances or redeterminations at scheduled renewals that otherwise would result in termination. This is to ensure all medical benefits remain open for TANF, ABD, LTC, CWS and DDS.  These populations must have had open medicaid benefits on or after March 18, 2020.

While this mandate is for Medicaid (SoonerCare) benefits only, these populations may experience other benefit related changes.

OHS/DHS should make a good faith effort to identify and reinstate clients whose medical benefits was terminated on or after the date of March 18, 2020 for reasons other than a voluntary request for termination or who have moved to another state.

Medicaid benefits should be reinstated back to the date of closure utilizing the same income, resources, and household composition listed on the case prior to the closure. Case notes will need to be updated with the following:

Pursuant to the CARES Act, Medicaid will remain open during the public health emergency-COVID-19.

Staff will need to keep track of these cases in order to take the appropriate closure action once the mandate is over.

Please note:  The only cases that can be closed during this public health emergency are individuals who request a voluntary termination, deceased individuals or individuals who have moved out state.


As of March 18, 2020, clients who have pending appeals medical benefits are to remain open and not be closed until the month COVID-19 ends.

Direct all questions or concerns regarding this directive to the HR&MS mailbox.

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