On August 13, the Centers for Medicare and Medicaid Services (CMS) issued its highly anticipated revisions to previous guidance on the resumption of normal Medicaid operations (or “unwinding”) when the COVID-19 Public Health Emergency (PHE) expires. Key revisions to previous guidance include:
- Extending the timeframe for completing pending eligibility and enrollment actions to up to 12 months post-PHE
- This does not change previous guidance on resuming timely processing of applications within four months post-PHE.
- Completing an additional redetermination for individuals determined ineligible for Medicaid during the PHE
- This rescinds the option under previous guidance for states to rely on an eligibility action processed within six months of the date of coverage termination post-PHE. In effect, the six-month “lookback” option for an eligibility action is no longer available.
- States must make a full redetermination prior to taking an adverse action with respect to any beneficiary.
- CMS reiterates that 30 days for beneficiary response to state requests to verify eligibility, along with minimum of 10 days of advance notice and fair hearing rights prior to termination or other adverse action, are required.
- States must take steps to transition beneficiaries determined ineligible to other insurance affordability programs.
CMS reminds states of the requirement in previous guidance to adopt one of four risk-based approaches to prioritize completion of pending work. CMS encourages states to revise any existing plans considering the new 12-month timeframe for this work. CMS will require states to consider the promotion of coverage continuity within the state’s chosen risk-based strategy. More guidance will be issued on this topic and to assist states in establishing renewal workloads that will be sustainable into the future.