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CMS Updates Guidance for Medicaid After COVID-19

In an Aug. 13 letter to state health officials, the Centers for Medicare & Medicaid Services (CMS) updates its guidance regarding the resumption of normal state Medicaid, Children’s Health Insurance Program (CHIP), and Basic Health Program (BHP) operations when the COVID-19 public health emergency ends.

During the pandemic, CMS relaxed several Medicaid, CHIP, and BHP program requirements to allow states to better respond to the pandemic. The Families First Coronavirus Response Act provided states additional funding for their Medicaid programs through increased Federal Medical Assistance Percentage. To receive this funding, the law required states to allow beneficiaries to be continuously enrolled in Medicaid and to not disenroll them from the program regardless of a change in their eligibility status.

The letter offers guidance and policy changes to support states’ return to prepandemic eligibility and enrollment practices and procedures once the public health crisis ends. The guidance largely reflects a December 2020 state health official letter, with two key changes:

  • CMS extends the timeframe for states to complete pending eligibility and enrollment actions from six months to up to 12 months after the month in which the public health emergency ends; and
  • CMS will require states to complete an additional redetermination for individuals ineligible for Medicaid during the public health emergency before terminating coverage.

Further, the letter asks states to reassess their risk-based approach to prioritizing pending eligibility determinations, which was a requirement in the December 2020 guidance, and make adjustments to their plans to restore routine operations after the PHE ends, as appropriate.

Contact Senior Director of Policy Erin O’Malley at eomalley@essentialhospitals.org or 202.585.0127 with questions

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About the Author

Abigail Painchaud is a policy associate at America's Essential Hospitals.

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