The CMS released guidance addressing the implementation of Section 71109 of the One Big Beautiful Bill Act (OBBBA, P.L. 119-21), which requires states to complete eligibility redeterminations once every six months, beginning with renewals starting on or after Jan. 1, 2027, for most individuals enrolled in the Medicaid adult group. Redetermination changes also extend to coverage under a waiver, such as those through section 1115 demonstrations. Regulations before the passage of OBBBA allowed for states to redetermine eligibility once every 12 months. The guidance provides states an overview of the changes to federal renewal requirements made by section 71107, reminds states of federal renewal requirements that continue to apply, and addresses operational considerations for states when implementing six-month renewals for the affected population.
Specifically, the CMS offered clarification on the language with respect to redeterminations scheduled on or after Jan. 1, 2027, as the agency agrees its language is ambiguous and could describe a change to the date for a scheduled renewal to be initiated in 2027 or could refer to setting a future initiation date for an individual’s next renewal. The agency will now provides two options for states. Option one would refer to “scheduled” as a renewal initiation date and would shorten the current eligibility period to six months. Option two would refer to “scheduled” as the act of setting a future renewal initiation date and would not reschedule the current eligibility date but would apply a six-month eligibility period moving forward to the first renewal conducted in 2027.