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CMS Releases PHE Unwinding Guidance for Medicaid Renewals

The Centers for Medicare & Medicaid Services (CMS) released a new State Health Official letter and other resources to help states prepare for the COVID-19 public health emergency (PHE) unwinding and return to regular Medicaid program operations.

The guidance prioritizes preventing erroneous terminations of Medicaid benefits. States must develop plans for their return to regular operations that outline how they intend to address outstanding determination actions in an efficient manner, ensure a sustainable distribution of renewals in future years, and guarantee timely processing of new applications.

The letter also reviews:

  • timelines to return to routine eligibility: since many states take 60–90 days to complete the renewal process, when the PHE ends, states will have:
    • 12 months to initiate renewals related to the unwinding of the PHE;
    • 14 months to complete renewals; and
    • four months to start the timely processing of new applications;
  • guidelines for establishing new renewal dates: states have flexibility to initiate renewals at any time during the 12-month unwinding period and are encouraged to align renewals for individuals within households or recertification timing with human services programs, such as the Supplemental Nutrition Assistance Program;
  • information about how to prioritize and distribute renewals: CMS expects states to prioritize pending eligibility and enrollment actions by population (e.g., individuals who have reported a decrease in income), by time (i.e., processing the oldest cases first), a combination of those factors, or another customized approach; and
  • strategies to prevent churn and transition to marketplace coverage: to avoid inappropriate terminations and future backlogs, CMS recommends the states initiate renewals of no more than one-ninth of their total caseload per month. States will be required to submit a distribution plan to CMS so the agency can identify states at risk of inappropriate coverage losses.

CMS will allow the limited use of section 1902(e)(14)(A) authority to provide administrative relief to states facing operational issues to promote continuity of coverage and to mitigate churn. The letter also reviews previously released guidance on strategies to promote continuous coverage and facilitate transitions from Medicaid to marketplace coverage. State agencies are required to have an agreement with the relevant marketplace and coordinated process to send beneficiary information to and from the marketplace.

States must submit data demonstrating progress in completing pending applications and initiating renewals, including baseline data and additional monthly reports. States not meeting the timelines described in this letter may be subject to a corrective action plan.

Other resources include:

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


About the Author

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

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