CMS Issues Guidance for Medicaid Programs on “Unwinding Period” for PHE Continuous Coverage Provisions

The Centers for Medicare and Medicaid Services (CMS) has issued guidance for state Medicaid Programs setting out how an ‘unwinding period’ for PHE continuous coverage provisions could proceed:

The guidance establishes a 12-month period during which Medicaid programs could complete re-determinations of enrollees afforded continuous coverage during the PHE:

The guidance will permit states to conduct a more aggressive re-determination effort. States could, potentially, begin re-determinations as soon as 60-days prior to any announced PHE termination, with loss of enrollee coverage, based upon review, to commence as early as 60-days after the end of the PHE.