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New CMS Resource on Medicaid Eligibility and Enrollment Processing Requirements

A new Centers for Medicare and Medicaid Services (CMS) resource for states highlights federal requirements for renewals, verifications, applications, and oversight of CMS programs in the context of the COVID-19 public health emergency (PHE) unwinding.

CMS reviews opportunities to streamline renewals during the PHE, such as improving ex parte renewal rates, and discusses the distribution of renewals over the unwinding period. CMS warns that states initiating renewals too quickly risk inappropriate terminations in violation of federal regulations, churn, and a high volume of fair hearing requests.

States may seek through waivers or state plan authority flexibility in verifying program eligibility, such as post-enrollment verification, use of income determinations from the Supplemental Nutrition Assistance Program or other service programs, or changes to the modified adjusted gross income verification plan.

Finally, CMS anticipates an increase in the number of fair hearing requests and encourages states to seek authority for additional time to process these requests.

For all CMS guidance and resources related to Medicaid and the PHE unwinding, visit

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Julie Kozminski is a senior policy analyst at America's Essential Hospitals.

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