CMS Guidance on Expectations for State Compliance with Medicaid and CHIP Renewal Requirements

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. For more information on how to subscribe and to activate a complimentary one week trial to Manatt on Health, please reach out to Barret Jefferds.     

On September 20, 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 Center for Medicaid and CHIP Services (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 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 mitigation strategies¹ 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 requirements² and describes the plan for addressing deficiencies to achieve full compliance by December 31, 2026.

For more information on how to subscribe and to activate a complimentary one week trial to Manatt on Health, please reach out to Barret Jefferds.

_{¹ Also see CMS, Preliminary Overview of State Assessments Regarding Compliance with Medicaid and CHIP Automatic Renewal Requirements at the Individual Level, as of September 21, 2023.}

_{² See 42 C.F.R. §§ 435.916 and 457.343}