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CMS Updates Key Dates for Medicaid Redeterminations

A Jan. 5 bulletin from the Centers for Medicare & Medicaid Services (CMS) Center for Medicaid and CHIP Services highlights key dates related to Medicaid continuous enrollment. Under the Families First Coronavirus Response Act, states claiming a temporary 6.2 percent increase in the federal medical assistance percentage (FMAP) were unable to terminate enrollment for most individuals enrolled in Medicaid due to the COVID-19 public health emergency (PHE). This increased FMAP and continuous enrollment requirement were to end when the PHE ends.

Under the Consolidated Appropriations Act, 2023, the increased FMAP and continuous enrollment requirement no longer are tied to the end of the PHE. The Medicaid continuous enrollment requirement will end March 31. On April 1, states may begin to terminate Medicaid enrollment for individuals who no longer qualify, while the increased FMAP will decrease gradually through Dec. 31.

States still will have 14 months to return to routine eligibility determinations. Now that states can start to disenroll individuals April 1, they can begin redeterminations Feb. 1. States initiating renewals on Feb. 1, must submit their renewal distribution plan and system readiness artifacts (testing and configuration plans) before this date. All other states must submit these materials to CMS by Feb. 15. All states must submit baseline unwinding data on the 8th of the month in which they start their renewals.

CMS will issue future guidance on the conditions to continue receiving the increased FMAP beginning April 1, reporting requirements, and additional information about the return of normal Medicaid operations in the following weeks.

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

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

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