CMS is now giving states a full year after the COVID-19 public health emergency ends to finish redetermining eligibility for Medicaid beneficiaries.
The agency announced the new guidance in a letter sent to state health officials Friday. The Families First Coronavirus Response Act prohibited Medicaid programs from kicking beneficiaries off the program regardless of changes in eligibility. That's caused Medicaid and Children's Health Insurance Program enrollment to swell to a record high of more than 81 million people this year.
Once the public health emergency ends, however, state health officials will be faced with the daunting task of combing through their Medicaid rolls to see who is still eligible.
"CMS believes the additional time is appropriate given the increased program enrollment and to ensure states can reestablish a renewal schedule that is sustainable in future years," Medicaid and CHIP Director Daniel Tsai wrote in the letter to state officials.
The letter does not signal the end of the public health emergency, nor does it indicate when the emergency declaration will end, Tsai wrote. HHS Secretary Xavier Becerra issued the most recent 90-day COVID-19 public health emergency declaration on July 19. The COVID-19 declaration has been renewed six times since early last year.
CMS originally gave states six months to sort out their Medicaid populations when it issued guidance in December.
"Having that time and the flexibility to space this work out to avoid a large number of renewals at the same time annually going forward is appreciated," Matt Salo, executive director of the National Association of Medicaid Directors, wrote in an email.
States that spent time planning out their redetermination process based on CMS' previous guidance could see some challenges in modifying those plans, however, Salo said.
The time frame for processing Medicaid applications following the public health emergency is not changing. States will still have up to 4 months after the month in which the public health emergency ends to resume timely processing of all applications.
A January report from The Commonwealth Fund suggested CMS give states longer than four months to return to their usual application timeliness standards. Citing legal precedent, the report said the risk of erroneously covering people is outweighed by the risk of denying them assistance.
"Pandemic conditions clearly propel the equities even more strongly in the direction of averting incorrect denials and coverage losses," The Commonwealth Fund report says.
The new CMS guidance also requires states to complete additional redeterminations after the public health emergency before terminating coverage for beneficiaries who were found to be ineligible during the pandemic. Beneficiaries whose circumstances changed must be given reasonable time—30 days, in CMS' estimation—to provide information or documentation that establishes eligibility. For those are determined to be ineligible, states are required to take steps to smoothly transition them to alternative coverage, if available.
Medicaid and CHIP enrollment grew by almost 10 million—about 14%—between February 2020 and January 2021, according to data CMS released in June.
