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 August 30, 2023, the Centers for Medicare & Medicaid Services (CMS) issued a State Medicaid Director Letter (SMDL) instructing states to assess whether they are in compliance with federal Medicaid regulations that require all renewal processes be conducted at the individual level. As part of its ongoing work with states to adopt and implement strategies to remediate areas of non-compliance with the federal renewal requirements and ensure that eligible individuals retain coverage during unwinding, CMS recently determined that some states may be conducting ex parte renewal processes at the household level, rather than at the individual level. The SMDL lays out immediate actions that states must take to determine if they are out of compliance with the federal renewal requirements and mitigate compliance issues.
This expert perspective summarizes the SMDL and additional considerations for states as they evaluate whether, and the extent to which, their renewal policy, processes, and systems are out of compliance with federal requirements to redetermine eligibility on an individual enrollee basis.
To view the full expert perspective, click here.