CMS extends deadlines for Medicaid redeterminations after COVID-19 public health emergency ends

MM Curator summary


States now have 12 months (instead of 6) to conduct re-determination exercises once the PHE is declared over.


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Dive Brief:

  • CMS is extending the timeframe states have to complete pending verifications, redeterminations based on changes in circumstances and renewals for Medicaid, the Children’s Health Insurance Program and Basic Health Program beneficiaries after the federal public health emergency for COVID-19 ends, according to a Friday letter from the agency.
  • Due to significantly increased workloads, state health officials will now have 12 months instead of six after the PHE ends to complete those tasks. It doesn’t change the four-month timeframe after the PHE ends that they have to resume the timely processing of all applications, however.
  • The letter also does not confirm when the federal PHE will end, as it has been extended multiple times. CMS will provide additional detailed guidance on the updated policies in the coming months, it said.

Dive Insight:

Enrollment in Medicaid and CHIP has grown to a record high, with more than 81 million beneficiaries. That’s largely due to the Medicaid continuous enrollment requirement tied to pandemic relief legislation that ceased typical churn, according to the letter.

A disruption in operations caused by the pandemic and the continuous enrollment requirement mean states will be faced with high volumes of eligibility and enrollment actions they’ll need to complete after the PHE and flexibilities that came with it end to ensure eligible beneficiaries don’t lose coverage.

States expressed concern that the original six-month timeframe CMS gave in December 2020 to complete growing backlogs would result in a “renewal bulge,” causing greater administrative burden that could be much more manageable within a larger time frame, according to the letter.

Beneficiaries also risk losing coverage if states held to that timeframe are unable to conduct outreach and put in place strategies to make accurate redeterminations and renewals.

The previous guidance also allowed states to avoid completing another redetermination before terminating coverage after the PHE ends if certain conditions are met, including that eligibility actions processed during the PHE were finished within six months of the beneficiary’s termination after the PHE.

But allowing states to avoid “repeat redeterminations” carries the risk that coverage will be terminated for some eligible beneficiaries, and CMS is rescinding that option in the new guidance. 

Under the updated policy, states can’t terminate any person determined eligible for Medicaid during the PHE, including people who failed to respond to requests for information, until the state has completed a redetermination after the PHE ends.

Before taking an adverse action toward any beneficiary, states must complete an additional redetermination that includes checking available information and data sources without contacting the beneficiary and requesting documents to obtain reliable information when eligibility cannot be renewed based on available information, according to the letter.

With the extended timeframe, CMS said states should reassess their risk-based approach to prioritizing pending work and prepare to restore routine operations after the emergency ends. Their risk-based approach should promote continuity of coverage for those eligible and limit delays in processing for those newly eligible or eligible for more comprehensive coverage.

“CMS is available to provide technical assistance to states that are working to complete pending eligibility and enrollment work within the 12-month timeframe, and we remain interested in hearing state feedback and concerns as states plan for and resume routine operations consistent with the expectations outlined in this letter,” the agency said.

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