This overview is excerpted from Manatt on Health, Manatt’s subscription service that provides in-depth insights and analysis focused on the legal, policy and market developments.
On August 29, 2024, the Centers for Medicare & Medicaid Services (CMS) released a Center for Medicaid & Children’s Health Insurance Program (CHIP) Services (CMCS) Informational Bulletin (CIB) and an accompanying slide deck to support states that continue to face renewal backlogs. With this guidance, CMS is providing states additional time—until December 31, 2025—to complete Medicaid and CHIP eligibility renewals, address persistent backlogs in processing redeterminations, and achieve compliance with federal renewal timeliness requirements.
- Timeline for Processing and Distributing Renewals. Through the CIB, CMS gives states the ability to continue to delay timely processing1 of certain renewals until December 31, 2025, specifically:
- Unwinding-related renewals: By December 31, 2025, states must make a final eligibility determination for all individuals who were enrolled in Medicaid and CHIP when the Medicaid continuous coverage requirement expired on March 31, 2023.
- Non-unwinding-related renewals: States may also continue to delay and/or redistribute non-unwinding-related renewals2 through December 31, 2025 for the purpose of ensuring a more even distribution of redeterminations that is sustainable in future years.
- Beginning with renewals initiated January 1, 2026: States must “return to regular business” and ensure timely processing, consistent with federal regulations and state timelines.
CMS provides specific conditions to which states must adhere in developing their plans for redistributing renewals (e.g., a state may not shorten an enrollee’s eligibility period). States must document their approach in their internal unwinding plans,3 and inform CMS (CMSUnwindingSupport@cms.hhs.gov) if their unwinding timelines have changed. Further, CMS directs states that are not on track to comply with the timelines outlined in the guidance to reach out to CMS as soon as possible, noting that non-compliance may result in a corrective action plan.
1 This authority exists under 42 C.F.R. §§ 435.912(e) and 457.340(d).
2 A non-unwinding-related renewal refers to a second or subsequent renewal following the end of the Medicaid continuous coverage requirement or a first renewal for an individual who enrolled after March 31, 2023.
3 States must make their plans available to CMS upon request or, as needed, for audit purposes.
