How have recent federal rule changes (post-2020) impacted California Medi-Cal continuous coverage and disenrollment?

1. How the federal change ended “guaranteed” continuous coverage — and what California did next

The federal Consolidated Appropriations Act of 2023 delinked the Medicaid continuous coverage requirement from the COVID public health emergency and effectively ended the guarantee of no disenrollments on March 31, 2023; California therefore resumed normal redeterminations on April 1, 2023 and began an “unwinding” period to process renewals for roughly 15 million enrollees ^[1]. The state set up outreach and operational tools (including DHCS toolkits and Coverage Ambassadors) to notify and assist beneficiaries; despite that, counties had to restart full redeterminations and contact enrollees to update information ^{[4] [5]}.

2. The scale and character of disenrollments during the unwinding

California processed nearly 11 million renewals during the unwinding and about two million people ultimately lost Medi‑Cal, with nearly 90% of initial disenrollments attributable to procedural reasons (for example, not returning forms or having missing/inaccurate information) rather than documented ineligibility ^{[2] [6]}. CHCF and other analysts estimate the “unwinding” could have led to two to three million people leaving the program, and final 90‑day updates showed 1,998,710 disenrollments tied to the renewal process ^{[1] [2]}.

3. Who was most affected — equity and practical implications

Multiple advocacy and research organizations warned that administrative churn would disproportionately hurt vulnerable groups — children, people with unstable housing, and those who changed addresses or phone numbers — because missed notices or paperwork barriers drive procedural disenrollment ^{[7] [6]}. Reports also document increased strain on safety‑net providers and hospitals as recently disenrolled people seek care in emergency settings ^[8].

4. Federal fiscal and policy shifts after 2023 that affect California’s decisions

Beyond the end of continuous coverage, later federal actions in 2025 — notably H.R. 1, as reported by the Legislative Analyst’s Office and others — significantly altered Medicaid financing and eligibility rules, projected to cut federal funding and potentially produce further disenrollments; the LAO flagged potential lost federal dollars and an uncertain but possibly large reduction in enrollment tied to those federal policy changes ^[3]. CHCF and budget analysts describe H.R. 1 as a major new constraint on California’s options ^[3].

5. California’s state‑level policy responses and budget trade‑offs

California has enacted and considered multiple state measures in response: changes to asset limits for seniors, expansions of coverage for some immigrant groups at state cost, and programmatic rollbacks or freezes for others. For example, the state’s asset test removal in January 2024 increased senior enrollment, and later state budget actions and trailer bills in 2025 modified enrollment rules for undocumented adults and restored some asset limits — each move shifts costs between state and federal coffers and affects caseloads ^{[3] [9] [10]}. These state choices reflect fiscal pressure from higher caseloads after the pandemic-era expansions and the subsequent federal funding changes ^{[11] [3]}.

6. Administrative fixes and recommended reforms coming out of the unwinding

Enrollees and advocates recommend clearer communications, simplified renewal forms, improved customer service, and better tracking to reduce preventable procedural disenrollments — recommendations CHCF summarizes after interviews and data analysis of the unwinding ^[6]. California also implemented targeted consumer protections such as Transitional Medi‑Cal for some groups, which aims to soften coverage loss tied to income changes ^[12].

7. What’s not addressed in the reporting provided

Available sources do not mention detailed county‑by‑county operational performance beyond statewide dashboards, nor do they provide a definitive, up‑to‑date headcount of disenrollments after January 2025 beyond the figures cited ^{[2] [13]}. Sources also do not settle the exact future trajectory of disenrollment after 2025 because pending federal/state laws and budget choices (such as implementation details of H.R. 1 consequences) remain uncertain in the material provided ^[3].

Final takeaway: ending the federal continuous coverage rule triggered an extensive statewide renewal effort that produced large, mostly procedural disenrollments; subsequent federal legislation and state budget moves in 2024–2025 have intensified fiscal pressure and produced further policy shifts that will likely shape Medi‑Cal enrollment and disenrollment trends going forward ^{[1] [2] [3]}.