State Health and Value Strategies (SHVS) developed this resource page to serve as an accessible one-stop source of information for states in “unwinding” the Medicaid continuous coverage requirement. The Families First Coronavirus Response Act (FFCRA) Medicaid continuous coverage requirement allowed people to retain Medicaid coverage and get needed care during the pandemic. On December 29, 2022, President Biden signed into law the Consolidated Appropriations Act, 2023 (CAA), an omnibus funding package that decoupled the continuous coverage provision from the end of the COVID-19 public health emergency by providing a fixed end date of March 31, 2023. These resources are designed to support states during this major coverage event, including developing processes that prioritize coverage retention. SHVS will update this page frequently with new resources as they become available. For more information about how states are unwinding the continuous coverage requirement, SHVS is highlighting examples of the work states are engaging in to prepare for and operationalize unwinding in our series States of Unwinding.
State Health and Value Strategies (SHVS) developed this resource page to serve as an accessible one-stop source of information for states in “unwinding” the Medicaid continuous coverage requirement. The Families First Coronavirus Response Act (FFCRA) Medicaid continuous coverage requirement allowed people to retain Medicaid coverage and get needed care during the pandemic. On December 29, 2022, President Biden signed into law the Consolidated Appropriations Act, 2023 (CAA), an omnibus funding package that decoupled the continuous coverage provision from the end of the COVID-19 public health emergency by providing a fixed end date of March 31, 2023. These resources are designed to support states during this major coverage event, including developing processes that prioritize coverage retention. SHVS will update this page frequently with new resources as they become available. For more information about how states are unwinding the continuous coverage requirement, SHVS is highlighting examples of the work states are engaging in to prepare for and operationalize unwinding in our series States of Unwinding.
CMS published a report highlighting the agency’s Fiscal Year 2023 COVID-19 Public Health Emergency response and use of section 1135 waivers and other flexibilities. CMS uses emergency section 1135 waivers to ensure program participants have access to services during a national emergency and that providers have the flexibility to provide and be paid for services. The report focuses on six key areas, including vaccines and therapeutics, testing, telehealth, emergency reporting, surge capacity, and long-term care facilities. The report summarizes CMS’ policy response and synthesizes external feedback gathered from a variety of sources. It also includes discussions and recommendations on several cross-cutting issues, such as workforce capacity, healthcare disparities, quality improvement and patient safety, and process improvements in the execution of section 1135 waivers and flexibilities.
On December 20, CMS issued an informational bulletin which provides guidance to help states effectuate a requirement that states seamlessly transition eligible children between Medicaid and separate CHIP beginning June 3, 2024. With this guidance, CMS is also exercising enforcement discretion and will not require state compliance with the following requirements until June 3, 2026: (1) that states send combined notices when a Medicaid-enrolled child is determined eligible for separate CHIP (and vice versa) , and (2) that states transfer accounts of individuals who are procedurally disenrolled from Medicaid or CHIP to the Marketplace.
On December 20, CMS issued an informational bulletin which outlines requirements related to renewal forms that states provide to Medicaid and CHIP enrollees. CMS offers detailed guidance on the required elements of the renewal form (e.g., which information should be requested and prepopulated), and the required modalities and timelines associated with the renewal form. The appendix to the guidance also includes a checklist that states may refer to for the elements that should be included in their renewal forms.
CMS issued a Center for Medicaid and CHIP Services Informational Bulletin on basic requirements for conducting ex parte eligibility renewals (or renewals based on reliable information available to the state) for Medicaid and CHIP enrollees. The guidance is a follow-up to its guidance on continued use of unwinding-related section 1902(e)(14) waivers and verifying financial eligibility, focusing on state implementation of federal ex parte renewal requirements and offering new state flexibility designed to increase ex parte renewal rates.
In follow-up to its September guidance on state compliance with federal renewal requirements, CMS issued a supplemental document specifying the “evidence” that states must submit to CMS by December 31 as part of their post-unwinding compliance plans, and a CMCS Informational Bulletin outlining state requirements and flexibilities for verifying financial eligibility (also see the accompanying slide deck). This new guidance is intended to support states in verifying eligibility and conducting renewals in compliance with federal Medicaid and CHIP requirements by December 2026.
This slide deck is intended to: 1) Provide an overview of and support state compliance with federal Medicaid and CHIP eligibility renewal requirements in place as of September 2024; 2) Serve as a supplementary resource to the State Compliance with Medicaid and CHIP Renewal Requirements by December 31, 2026 CMCS Informational Bulletin and additional, forthcoming guidance related to renewal compliance; 3) Acknowledge new federal regulatory requirements for completing renewals and associated compliance dates to assist states in their planning for policy, operational, and IT systems changes as they streamline non-Modified Adjusted Gross Income (MAGI) Medicaid renewal processes to align with those for MAGI Medicaid and CHIP.
CMS released an informational bulletin to provide updated information on the timing and expectations for states to achieve compliance with all federal Medicaid and CHIP renewal requirements. To accompany the informational bulletin, CMS also released a compliance template, which states should use to submit their compliance plans by December 31, 2024. Compliance plans will detail how states will achieve compliance with all applicable requirements no later than December 31, 2026.
CMS released an informational bulletin to provide updated information on the timing and expectations for all states to achieve compliance with all federal renewal requirements, including states that implemented CMS-approved mitigation strategies and those who have since identified areas of non-compliance with renewal requirements. All states are required to complete a compliance assessment, demonstrate compliance with federal Medicaid and CHIP renewal requirements, and submit a plan outlining steps and milestones for addressing identified areas of non-compliance to CMS by December 31, 2024. Compliance plans will detail how states will achieve compliance with all applicable requirements no later than December 31, 2026.
This slide deck presents approaches that states can implement temporarily and on an ongoing basis to come into compliance with federal regulations on timely processing of Medicaid and CHIP eligibility renewals, including: options for processing renewals pending more than six months; time-limited strategies for renewal processing; and ongoing practices to support timely renewal processing.
CMS is providing states additional time to complete eligibility renewals, address persistent backlogs in processing redeterminations, and ensure that states achieve compliance with federal renewal timeliness requirements by December 2025. This informational bulletin outlines the duration and conditions under which states may rely on an exception to those requirements.
CMS recently released an interim, preliminary overview of states’ scheduled timelines for completion of unwinding-related renewals as an update to prior estimates (CMS last provided an update on state unwinding timelines in June 2023). The document reflects preliminary estimates of states’ scheduled timelines to complete a first renewal for individuals who were enrolled in Medicaid or CHIP as of the beginning of the state’s unwinding period. The document also states that additional guidance related to renewal processing and an updated table with state timelines for completion of all unwinding-related renewals is forthcoming.
SHO #24-002 indefinitely extends state reporting of certain Medicaid and CHIP metrics required by the Consolidated Appropriations Act, 2023. The CAA reporting requirements on renewal outcomes were set to expire on June 30, 2024. CMS will also continue reporting state and national data publicly on renewal outcomes.
To remind states of their obligation to process Medicaid and CHIP applications in compliance with federal requirements and help states improve timely processing, CMS released an Informational Bulletin and accompanying slide deck highlighting effective policies and practices that states may consider taking up during and after unwinding.
To remind states of their obligation to process Medicaid and CHIP applications in compliance with federal requirements and help states improve timely processing, CMS released an Informational Bulletin and accompanying slide deck highlighting effective policies and practices that states may consider taking up during and after unwinding.
CMS released an Informational Bulletin announcing an extension of section 1902(e)(14) strategies and other unwinding-related flexibilities through June 30, 2025, while CMS continues to assess which section 1902(e)(14) waivers it can authorize permanently.
CMS announced the extension of the temporary special enrollment period (SEP) for individuals no longer eligible for Medicaid or CHIP to enroll in Marketplace coverage. The end date of the “Unwinding SEP” will be extended from July 31, 2024, to November 30, 2024.
CMS released a suite of Medicaid unwinding-related guidance and enrollment data that includes a focus on ensuring eligible children maintain Medicaid and CHIP coverage. In conjunction with CMS’ release, HHS sent letters to the governors of nine states with the highest child disenrollment rates, which accounted for 60% of the decline in children’s enrollment between March and September 2023. The letters encourage the nine states to adopt certain strategies to mitigate coverage loss for eligible children.
CMS published and made effective an interim final rule with comment period regarding states’ ongoing unwinding efforts to redetermine eligibility for all Medicaid enrollees.
This CMS chart identifies states that requested concurrence to delay procedural disenrollments for enrollees during the return to routine Medicaid renewals period, including information on the number of months for the delay, the duration of the authority, and affected populations. This chart only identifies states that have opted to pause procedural disenrollments to allow time for targeted outreach. It does not identify states that received CMS approval to delay procedural disenrollments as part of a mitigation strategy.
CMS published a slide deck that provides further information on operationalizing continuous eligibility for children after an ex parte renewal.
CMS published an interactive map and updated table of the section 1902(e)(14) waivers approved for states and territories to facilitate unwinding, including strategies to support ex parte processes.
CMS published preliminary state-reported information about the ability of states’ systems to conduct automatic renewals, otherwise known as ex parte renewals, at the individual level. As of September 21, 23 states and territories attested to correctly conducting ex parte renewals at the individual level, while 30 states and territories indicated they are not doing so or are still working to reinstate affected individuals. In a press release, CMS announced that all 30 states and territories are required to pause procedural disenrollments for impacted people unless they can ensure all eligible people are not improperly disenrolled as a result of the systems issue.
CMS published a table that presents preliminary state-reported information about the ability of states’ systems to conduct automatic renewals, otherwise known as ex parte renewals, at the individual level. As of September 21, 23 states and territories attested to correctly conducting ex parte renewals at the individual level, while 30 states and territories indicated they are not doing so or are still working to reinstate affected individuals.
CMS issued a State Medicaid Director Letter (SMDL) instructing states to assess whether they are in compliance with federal Medicaid regulations that require all renewal processes be conducted at the individual level.
CMS is calling to action every state and federal agency that works with children and families to engage directly and through partners during the unwinding to maintain coverage.
CMS published a summary of the mitigation strategies 35 states adopted to comply with Medicaid renewal requirements. The summary highlights specific areas where states were deemed out of compliance with the federal renewal requirements, and states’ primary, high-level mitigation strategies. Of note, nine states paused procedural terminations as part of their mitigation plan and 16 states did not identify areas of non-compliance and therefore did not adopt mitigation strategies.
A slide deck with account transfer strategies. CMS encourages states with State-Based Marketplaces to consider exchanging information on procedural terminations and jointly conducting outreach—including with regard to the 90-day reconsideration period for individuals terminated from Medicaid/CHIP.
An updated timeline chart with revised information on the month in which states initiated renewals and began processing terminations of Medicaid and CHIP coverage for individuals determined ineligible. The chart newly includes detail on the states that are prioritizing redeterminations for individuals they have identified as likely ineligible for Medicaid/CHIP.
CMS released frequently asked questions for state Medicaid and CHIP agencies on FMAP reduction and the failure to meet reporting requirements
CMS has confirmed that the termination of the national emergency does not impact the planned May 11 termination of the public health emergency (PHE), any associated PHE unwinding plans, or any existing 1135 waivers.
Frequently asked questions (FAQs) regarding implementation of the Families First Coronavirus Response Act (FFCRA), the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), and the Health Insurance Portability and Accountability Act (HIPAA). These FAQs have been prepared jointly by the Departments of Labor (DOL), Health and Human Services (HHS), and the Treasury. These FAQs answer questions from stakeholders to help people understand the law and benefit from it, as intended.
Building on existing CMS guidance, the State Health Official letter details the requirements that states must comply with in order to receive the enhanced federal medical assistance percentage; clarifies expectations for states to comply with the Medicaid, CHIP, and marketplace reporting elements required by the CAA; and reviews implications of the CAA on select COVID-19 public health emergency-related flexibilities and authorities.
The Centers for Medicare & Medicaid Services (CMS) released a document that provides detailed description of the configuration/implementation plan, testing plan, and testing results that states will need to submit when the continuous enrollment condition ends. This document aims help states understand systems readiness artifacts that are routinely submitted to CMS’ State Systems team during IT project and certification reviews. This release includes an FAQ, and also points to previously released systems guidance (Streamlined Certification Guidance, Testing and Automation resources, etc.).
CMS released an updated deck on Strategic Approaches to Engaging Managed Care Plans to Maximize Continuity of Coverage as States Resume Normal Eligibility and Enrollment Operations in Medicaid and the Children’s Health Insurance Program (CHIP), following the end of the COVID-19 Medicaid continuous enrollment requirement. The updated deck provides new examples and scenarios of ways health plans can engage with states and beneficiaries to support continuity of coverage during unwinding.
The Office of the Assistant Secretary for Planning and Evaluation published a report that provides current HHS projections of the number of individuals predicted to lose Medicaid coverage at the end of the COVID-19 public health emergency (PHE) due to a change in eligibility or due to administrative churning. The report also predicts eligibility for alternative insurance coverage among those predicted to lose Medicaid eligibility and highlights legislative and administrative actions that can help minimize disruptions in coverage, including the passage of the Inflation Reduction Act, which provides enhanced Marketplace subsidies for three years that will benefit some individuals leaving Medicaid at the end of the PHE.
The Centers for Medicare & Medicaid Services (CMS) released a new resource highlighting the states that have obtained CMS approval for various section 1902(e)(14) waivers to support “unwinding” from the Medicaid continuous coverage requirement. Among the 20 states with approved waivers, 70 percent have obtained flexibility to (1) conduct ex-parte renewals for individuals with no income and no data returned, and (2) accept updated enrollee contact information from managed care plans. Of note, one state (Alabama) has been granted “off-menu” authority to renew Medicaid eligibility for Temporary Assistance for Needy Families participants.
CMS posted an FAQ that says issuers that reduce or eliminate agent and broker commissions for enrollments through special enrollment periods (SEPs) are violating the guaranteed issue provisions of the ACA and doing so would constitute a discriminatory marketing practice.
The Centers for Medicare & Medicaid Services (CMS) released a new tool states can use to further prepare for the eventual end of the COVID-19 public health emergency (PHE) and return to normal Medicaid and Children’s Health Insurance Program (CHIP) eligibility and enrollment operations. Specifically, this tool highlights the ten fundamental actions states need to complete to prepare for unwinding when the Medicaid continuous enrollment requirement ends.
The Centers for Medicare & Medicaid Services (CMS) released a resource that reminds states of their obligation to continue to meet federal requirements related to eligibility and enrollment in Medicaid, the Children’s Health Insurance Program (CHIP), and the Basic Health Program (BHP) during the COVID-19 public health emergency unwinding period. This tool includes information for states on the requirements for eligibility renewals and redeterminations, application processing, fair hearings, coordination with the Marketplace, and other processes. Additionally, this resource highlights temporary options available to states during the unwinding period to facilitate eligibility and enrollment processing and retain coverage for eligible individuals.
HHS Secretary Becerra and CMS Administrator Brooks-LaSure sent a letter to governors discussing the flexibilities made available to states to support the unwinding of the continuous coverage requirement. The letter also includes a list of resources that HHS has issued to assist states with redeterminations, and reminds states that they should be putting in place processes to ensure coverage for Medicaid enrollees when the PHE ends.
On April 22, 2022, CMS released a proposed rule that would create a Medicare special enrollment period (SEP) to be timed with the end of the Medicaid continuous coverage requirement. CMS is proposing the SEP for individuals enrolled in Medicaid when they initially qualify for Medicare who do not enroll in Medicare coverage when they turn 65, resulting in a coverage gap if they are then determined ineligible for Medicaid coverage following the end of the continuous coverage requirement. The proposed SEP would allow individuals to enroll after termination of Medicaid coverage following the end of the federal public health emergency (PHE) without being subject to a late enrollment penalty.
HHS Secretary Xavier Becerra renewed the public health emergency as of April 16, extending it to July 15, 2022.
The Centers for Medicare & Medicaid Services (CMS) released a new tool for states to utilize as they prepare to return to normal eligibility and enrollment operations after the COVID-19 public health emergency. The tool provides states with a summary of best & promising practices gleaned from discussions that CMS had with Medicaid agency leadership from each state, DC and three U.S. territories. The tool includes information on strategies states are implementing related to outreach, enrollee communications, renewals, updating enrollee contact information and addressing workforce issues to support their preparation for returning to normal eligibility and enrollment operations after the COVID-19 public health emergency.
The Centers for Medicare & Medicaid Services (CMS) released a new tool for states to utilize as they prepare to return to normal eligibility and enrollment operations after the COVID-19 public health emergency. The tool provides states with strategic approaches for processing Medicaid fair hearings as states resume normal eligibility and enrollment operations. Contained in the tool are steps a state may want to take to assess their fair hearing process and capacity, strategies to address anticipated fair hearing volume, and how to request authority from CMS to implement a mitigation strategy if needed.
The Centers for Medicare & Medicaid Services (CMS) released additional templates and resources to support state reporting around enrollment and renewal efforts when the federal public health emergency (PHE) concludes. The resources include 1) a “Renewal Distribution Report” form in which states will be required to summarize their renewal plans, with a focus on mitigating inappropriate coverage loss during the unwinding period and 2) an “Unwinding Eligibility and Enrollment Data Reporting” Excel workbook and specifications document, which aims to support states in reporting on certain metrics around timely application processing, renewal initiation and completion, reason for termination, and fair hearings. CMS also previewed that states will eventually report on these metrics on a monthly basis.
CMS released a State Health Official letter outlining guidance to ensure states are well-prepared to initiate eligibility renewals for all individuals enrolled in Medicaid and CHIP within 12 months of the eventual end of the PHE and to complete renewals within 14 months. The new guidance provides reporting tools as well as an eligibility and enrollment tool.
HHS Secretary Xavier Becerra renewed the public health emergency as of January 16, extending it to April 15, 2022.
On November 24, CMS released a “punch list” of strategies states and the US territories can adopt to maintain coverage of eligible individuals as they return to normal operations after the end of the public health emergency. The strategies are organized around seven topics areas: (1) strengthening renewal processes; (2) updating mailing addresses; (3) improving consumer outreach, communication, and assistance; (4) promoting seamless coverage transitions; (5) improving coverage retention; (6) addressing strains on the eligibility and enrollment workforce; and (7) enhancing oversight of eligibility and enrollment operations. In this resource, CMS also flagged strategies they expect to have the biggest impact on mitigating coverage losses.
Updated Guidance Related to Planning for the Resumption of Normal State Medicaid, CHIP, and BHP Operations Upon Conclusion of the COVID-19 Public Health Emergency
Guidance on planning for the Resumption of Normal State Medicaid, CHIP, and BHP Operations Upon Conclusion of the COVID-19 Public Health Emergency
On January 6, 2021, CMS released an updated FAQ document that incorporates all eight sets of COVID-19 FAQs into one, comprehensive FAQ document.
CMS Expanding Coverage Under Medicaid and CHIP: Materials developed by the Expanding Coverage MAC Learning Collaborative for states.