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CMS Warns States about Medicaid Renewal Violations

The Centers for Medicare & Medicaid Services (CMS) on Aug. 30 warned state Medicaid directors about system and operational issues in multiple states that violate Medicaid renewal requirements.

After working with states over the past several months to return to normal Medicaid operations, CMS is concerned that conducting ex parte renewals at the household level without regard for household members’ different eligibility statuses and income thresholds has resulted in the erroneous disenrollment of individuals who are still eligible for Medicaid or CHIP.

To ensure compliance, CMS asks all states to review their renewal processes and test renewal logic in their eligibility system. Should states identify issues out of compliance, states are to:

  1. Pause procedural disenrollments for affected individuals.
  2. Reinstate coverage for all affected individuals.
  3. Implement CMS-approved mitigation strategies to prevent continued inappropriate disenrollments.
  4. Fix state systems and processes to ensure renewals are conducted appropriately and in accordance with federal Medicaid requirements.

States must notify CMS by Sept. 13 if they have identified areas of noncompliance and provide a remediation plan if applicable. States that fail to do so are subject to CMS compliance action, civil money penalties, and disqualification for the temporary increased federal medical assistance percentage.

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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