CMS extends Medicaid 'unwinding' waivers into 2025
By Nona Tepper / May 10, 2024
States have more time to make accurate and timely redeterminations of Medicaid and Children's Health Insurance Program eligibility as they continue unwinding the continuous coverage provisions derived from expired COVID-19 relief programs.
The Centers for Medicare and Medicaid Services issued a memo to state officials Thursday that extends federal regulatory waivers and flexibilities to June 2025, one year after they were slated to be discontinued. Since eligibility redeterminations resumed in April 2023, CMS has offered states a variety of tools they may use to identify and remove Medicaid and CHIP enrollees who no longer qualify and preserve coverage for those who do.
"Due to state adoption of strategies to prevent inappropriate disenrollments and other CMS-approved unwinding-related strategies, many states will continue conducting unwinding-related renewals beyond June 2024," Center for Medicaid and CHIP Services Director Dan Tsai wrote state officials Thursday.
These efforts are voluntary for states and takeup has varied widely. Nearly 22 million Medicaid and CHIP beneficiaries have been deleted from the rolls as of Friday, which amounts to 23% of those enrolled as of March 2023, according to government data compiled by KFF.
The vast majority of those disenrollments, or 69%, were procedural in nature, meaning states did not affirmatively ascertain whether those beneficiaries were ineligible but removed them for other reasons, such as being unable to contact them to obtain income and residency information.
In 2020, the federal government gave states enhanced Medicaid funding on the condition that they suspend eligibility redeterminations to prevent low-income people from becoming uninsured during an infectious disease outbreak. That policy expired March 31, 2023.
As the number of procedural disenrollments mounted last year, CMS redoubled its efforts to encourage states to be more circumspect and not take away coverage from qualified individuals. In September, CMS ordered 30 states to pause eligibility checks to stem the tide of procedural disenrollments. In December, the agency threatened to withhold Medicaid funding from states that deviated from federal rules.
“CMS will continue to monitor states’ activities to ensure that eligible individuals have access to the coverage to which they are entitled,” Tsai wrote.
Tsai informed states they will be permitted to maintain activities such as accessing income and residency information from other government agencies, permitting Medicaid managed care contractors to assist members with coverage renewals, and retroactively restoring coverage to people erroneously disenrolled.
“Many of the strategies adopted by states during their unwinding period will continue to be needed to protect beneficiaries while the states implement policy, systems and operational fixes to address areas of noncompliance with federal renewal requirements that were identified during unwinding,” Tsai wrote.
CMS previously extended the amount of time people who lose Medicaid or CHIP have to sign up for health insurance exchange plans and finalized a rule designed to ease Medicaid and CHIP enrollment. Under that regulation, for example, states will no longer need to request waivers to use beneficiary information from Medicaid insurers or from the U.S. Postal Service to verify eligibility.