State Medicaid departments will now have 14 months after the end of the COVID-19 public health emergency to complete Medicaid renewals and outstanding eligibility actions—though states still have to initiate all renewals and actions within 12 months, according to a new guidance letter sent to state officials Thursday.
The Centers for Medicare and Medicaid Services decided to elongate the timeline, based on concerns from states that said they typically can't complete a renewal in the same month in which it was started.
Concern over resuming Medicaid eligibility redeterminations at the close of the PHE is mounting among Medicaid officials and beneficiary advocates. States have had to maintain their Medicaid rolls during the pandemic to receive enhanced federal Medicaid funding, but that requirement is slated to end when the PHE designation culminates.
CMS has already released multiple guidance documents meant to guide states through the unwinding of continuous enrollment. But Medicaid watchers remain worried about not having enough time or resources to properly resume redeterminations once they begin.
In Thursday's letter, CMS further clarifies that states must begin the work for unwinding Medicaid continuous enrollment no later than the first of the month, following the end of the PHE. States can start their process up to two months before the PHE actually ends, CMS says, but coverage can't be terminated before then if states want to continue receiving the extra funding.
Officials have promised to give states at least a 60-day warning before pulling the designation, meaning the earliest it can expire is July.
CMS expects states to come up with a distribution schedule to start and process renewals and activities over the year after the PHE ends. In addition, CMS recommends states initiate no more than one-ninth of all open renewals per month during the unwinding period.
"States that do not make plans to distribute their work during the 12-month unwinding period run the risk of errors in processing renewals and inappropriately terminating coverage for eligible individuals—not only during the 12-month unwinding period but also in future years as distributing this work over a shorter period could create peaks in routine renewal volume in particular months," the guidance reads.
Aside from obliging states to submit information about how they plan to distribute renewals throughout the post-PHE period, the agency will also require states to present information, regarding the ways in which they plan to minimize inappropriate coverage loss—and use this information to figure out which ones are most at-risk for this. This is separate from the unwinding strategy plans that states have to develop; they aren't required to submit those plans to CMS for approval, although they will have to make the plans available to CMS upon request.
States can prioritize beneficiaries more likely to be eligible for different coverage or beneficiaries who've had the longest pending actions. They can take other approaches too, provided they keep with the goals of preventing churn, achieving a sustainable renewal schedule and easing transitions, the letter says.
CMS notes the unwinding period presents an opportunity to align renewals with other benefit recertifications, such as with the Supplemental Nutrition Assistance Program, or to align renewals for an entire household. The guidance outlines strategies for easing transitions from Medicaid into a qualified health plan, too.
States will be allowed to use temporary waivers to renew Medicaid eligibility for SNAP participants without conducting a separate income determination; permit renewals for households that verifiably attested to having no income within the last year but for whom no data was returned from a financial data source at renewal time; facilitate renewals for people with no Asset Verification System data returned in a timely fashion; accept updated enrollee contact information directly from managed care organizations; and take extended time to issue a final action on fair hearing requests.