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CMS Releases Updated Guidance on Medicaid Eligibility and Redeterminations

March 4, 2022

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CONTACTS
Mary Mullaney, Director, Hospital Payment Policies

On March 3, the Centers for Medicare & Medicaid Services released updated guidance regarding redeterminations of Medicaid beneficiary eligibility for when the public health emergency (PHE) ends. The PHE is currently set to expire on April 15, though it is expected that the administration will extend the expiration for at least an additional 90 days.

The new guidance provides planning and reporting tools to assist states as they transition back to pre-PHE Medicaid eligibility and enrollment operations at the end of the PHE. The guidance seeks to promote continuity of coverage and facilitate transitions between Medicaid, the Children’s Health Insurance Program, the Basic Health Program, and the Health Insurance Marketplaces.

The updated guidance will allow states to initiate, rather than complete, redeterminations during the 12-month unwinding period to reestablish a regular schedule of renewals. Additionally, states will be provided an extra two months before they initiate terminations to start the renewal process and until the end of the 14th month to complete all renewals, post-enrollment verifications, and redeterminations based on changes in circumstances.

Section 6008 of the Families First Coronavirus Response Act (P.L. 116-127) provides for a temporary increase of 6.2 percentage points in states’ Federal Matching Assistance Percentage (FMAP) during the PHE. States claiming the temporary FMAP increase must maintain beneficiary enrollment and coverage of all Medicaid beneficiaries through the end of the month in which the PHE ends. Under the previous guidance, states would have had 12 months to conduct full redeterminations for all enrollees when the continuous coverage requirements expire at the end of the PHE.

Additional information on the updated guidance can be found here.

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