State Medicaid departments will now have 14 months after the end of the COVID-19 public health emergency to complete Medicaid renewals and pending eligibility actions, although states still must initiate all renewals and actions within 12 months, according to new leadership sent to government officials on Thursday.
The Centers for Medicare and Medicaid Services decided to extend the deadlines based on the concerns of states, which said they usually cannot complete an extension in the same month that it was started.
Concern about the resumption of Medicaid eligibility after PHE is closed is growing among Medicaid officials and beneficiary advocates. States have had to maintain their Medicaid rosters during the pandemic in order to receive expanded federal Medicaid funding, but that requirement should end when PHE status culminates.
CMS has already issued several guidance documents designed to guide states in the process of phasing out continuous enrollment. But Medicaid watchdogs remain concerned they won’t have enough time or resources to properly resume re-determinations once they’ve begun.
In Thursday’s letter, CMS further clarifies that states must begin work to end continuous enrollment in Medicaid no later than the first day of the month following the end of PHE. States can start their process up to two months before the actual end of PHE, CMS said, but coverage cannot end sooner if states want to continue receiving additional funding.
Officials have promised to give states at least 60 days’ notice before canceling the appointment, meaning it will expire in July.
CMS expects states to develop a distribution schedule to begin and process updates and activities within a year of the end of PHE. In addition, CMS recommends that states initiate no more than one-ninth of all open renewals per month during the spin-up period.
“States that do not plan to expand their work during the 12-month roll-out period risk making renewal processing errors and inappropriately terminating coverage for eligible individuals—not only during the 12-month roll-out period, but in subsequent years as distribution. this work over a shorter period may result in peaks in routine updates in certain months,” the guide says.
In addition to the obligation for states to provide information on how they plan to allocate renewals during the post-PHE period, the agency will also require states to provide information on how they plan to minimize improper loss of coverage and use that information to calculate which ones are most affected. risk for it. This is not related to the broader strategic plans that states must develop; they are not required to submit these plans to the CMS for approval, although they will be required to make the plans available to the CMS upon request.
States may prioritize beneficiaries who are more likely to qualify for different coverage or beneficiaries who have the longest wait for action. They may use other approaches, as long as they adhere to the goals of preventing churn, achieving a sustainable renewal schedule and facilitating transitions, the letter says.
CMS notes that the roll-up period provides an opportunity to match renewals with other recertifications of benefits, such as the Supplemental Food Assistance Program, or to match family-wide renewals. The guide also outlines strategies for facilitating the transition from Medicaid to a qualified health plan.
States will be allowed to use temporary exemptions to renew Medicaid eligibility for SNAP members without a separate income determination; Renewal of permits for households that reliably verified no income during the last year, but for which no data was returned from the financial data source at the time of renewal; facilitate renewal for people who are not returned asset verification system data in a timely manner; accept updated enrolled contact information directly from managed care organizations; and additional time is required to make a final decision on Fair Hearing requests.