To: Oklahoma Licensed Producers, Oklahoma Licensed Health Insurers and HMOs and Other Interested Parties
Re: End of Medicaid Continuous Enrollment Period
From: Glen Mulready, Insurance Commissioner
Date: March 8, 2023


The Families First Coronavirus Response Act of 2020 (FFCRA) required state Medicaid agencies to continue coverage for enrollees through the COVID-19 Public Health Emergency (COVID-19 PHE). The Consolidated Appropriations Act decoupled the continuous enrollment period from the public health emergency effective April 1, 2023, which means the continuous enrollment period eligibility will also end. More than 300,000 Oklahomans currently enrolled in SoonerCare (Oklahoma Medicaid) are expected to be ineligible to participate in the program.

On December 29, 2022, the Consolidated Appropriations Act of 2023 was signed into law and includes a provision directing state Medicaid agencies to resume normal eligibility determinations as early as February 2023 as outlined by the Centers for Medicare & Medicaid Services (CMS). Termination of coverage or disenrollment based on eligibility determinations will take place beginning April 30, 2023 and over the remainder of 2023. Disenrollment timing will be based on criteria established by the Oklahoma Health Care Authority (OHCA), the state agency responsible for the SoonerCare program.

Impacted SoonerCare members will be sent a series of letters from the OHCA as follows: 1) an initial letter that renewals are restarting; 2) a second letter that identifies the end of coverage and the reason for the ineligibility; 3) a third letter, 45 days before the coverage end date, reminding the participant to update information on the on-line application; and 4) a fourth letter 10 days before coverage ends.

For those losing SoonerCare benefits, a special enrollment period (SEP) on the Affordable Care Act (ACA) marketplace has been established that will run from March 31, 2023 to July 31, 2024.  OHCA will send participant information directly to www.healthcare.gov, which will communicate information and assist with an ACA plan enrollment. An SEP also has been put into place for participants who are losing SoonerCare coverage and have access to employer-based coverage. The employee must request enrollment in the employer plan within 60 days of his or her termination date from SoonerCare.

Licensed agents, brokers, issuers, and other interested parties are strongly encouraged to assist individuals and families in understanding and facilitating enrollment in ACA plans or employer-based coverage.  Additionally, navigator entities across the state, organized by Legal Aid of Oklahoma (myOKplan.org) will be assisting with enrollments.

Regulated entities can direct inquiries to Mike Rhoads at mike.rhoads@oid.ok.gov and Rebecca Ross at rebecca.ross@oid.ok.gov at the OID.