CMS Revises Guidance for State Medicaid Programs on Post-Pandemic Planning
- August 20, 2021
The Centers for Medicare & Medicaid Services (CMS) issued August 13 revised guidance to Medicaid and Children’s Health Insurance Program state officials to assist with planning for when the COVID-19 public health emergency (PHE) ends.
Under guidance issued in December 2020, CMS said states would have six months after the month in which the PHE ends to complete pending post-enrollment verifications, redeterminations based on changes in circumstances, and renewals.
The revised guidance extends the timeframe for states to compete pending eligibility and enrollment actions up to 12 months after the month in which the PHE ends. The change responds to states’ concerns that they will need more time to complete the growing backlog of pending work.
“CMS believes the additional time is appropriate given the increased program enrollment and to ensure states can reestablish a renewal schedule that is sustainable in future years,” according to the guidance.
Given the additional time to complete pending eligibility and enrollment actions, however, CMS is rescinding an option under the previous guidance for states not to complete another redetermination for individuals who were determined ineligible for Medicaid during the PHE, but who were not terminated from the program because of the continuous enrollment requirement necessary to claim the temporary 6.2 percentage point increase in the federal medical assistance percentage.
CMS said the option in the December 2020 guidance for states to avoid “repeat redeterminations” risked terminating coverage for some eligible beneficiaries. Under the revised policy, states must complete an additional redetermination before taking any adverse action regarding any beneficiary.