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CMS Issues Guidance on Continuous Medicaid Coverage for Children

Starting Jan. 1, 2024, states must provide 12 months of continuous eligibility for children younger than age 19 in Medicaid and the Children’s Health Insurance Program (CHIP). The Centers for Medicare & Medicaid Services (CMS) on Sept. 29 sent state health officials a letter providing guidance on implementing this requirement from the Consolidated Appropriations Act, 2023.

Currently, states have the option to provide continuous eligibility for a shorter time period or elect a younger age limit. A child’s eligibility cannot be terminated during a continuous eligibility period unless:

  1. The child turns 19 or a younger age specified by the state.
  2. The child or the child’s representative requests a termination of eligibility.
  3. The child ceases to be a resident of the state.
  4. The agency determines that eligibility was erroneously granted at the most recent eligibility determination.
  5. The child is deceased.

CHIP eligibility can be terminated when the child becomes eligible for Medicaid or the family fails to pay premiums or enrollment fees, if applicable.

Beginning in 2024, states must provide continuous eligibility for children in Medicaid and CHIP for 12 months. Continuous eligibility can be terminated for the same reasons listed above, with the exception of age, but not for a change in their family’s circumstances.

CMS provides details on the beginning of continuous enrollment periods for new applicants as well as those following periodic eligibility renewal. For a child whose eligibility period ends after Jan. 1, 2024, and who experiences a change in circumstances, the child will remain enrolled for the remaining period of eligibility unless a terminating event occurs. For children whose eligibility was not renewed due to the COVID-19 public health emergency continuous enrollment requirement, their continuous eligibility period will begin when their renewal during the state’s unwinding occurs, provided they remain eligible.

Changes in circumstances experienced between renewal periods or identified in post-enrollment verification are not grounds for coverage termination.

The letter also provides guidance on considerations for specific populations, including Medicaid and CHIP eligibility for children who become incarcerated, and children covered through the from-conception-to-end-of-pregnancy option.

States without 12-month continuous eligibility for children in Medicaid and CHIP will need to submit a Medicaid or CHIP state plan amendment (SPA). States also must submit a SPA to comply if the state imposes continuous eligibility restrictions that are no longer permissible starting in 2024.

States also may use Section 1115 waiver authority to request continuous eligibility for children for more than 12 months, or multi-year continuous enrollment, as well as continuous eligibility for adults.

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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