Support for this expert perspective was provided by the State Health and Value Strategies program, a grantee of the Robert Wood Johnson Foundation. The views expressed here do not necessarily reflect the views of the Foundation.

On September 20, 2024, the Centers for Medicare & Medicaid Services (CMS) issued guidance detailing the timeline and expectations for states to fully comply with federal Medicaid and Children’s Health Insurance Program (CHIP) renewal requirements. This guidance—including a CMCS Informational Bulletin (CIB) and an accompanying template and slide deck—was developed in response to CMS identifying a number of issues with states’ eligibility and enrollment (E&E) systems and processes during the “unwinding” period. To address these challenges and prevent barriers to coverage and care for enrollees, CMS worked with states to implement mitigations, and made clear its expectation that all states eventually achieve full statutory and regulatory compliance with federal renewal requirements.

With this guidance, CMS is requiring every state to submit by December 31, 2024 a plan (using CMS’ template) that assesses state compliance with the federal renewal requirements at 42 C.F.R. §§ 435.916 and 457.343 and describes the plan for addressing deficiencies to achieve full compliance by December 31, 2026.

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