November in Review: CMS Issues Medicaid and CHIP Eligibility and Enrollment Guidance to States

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Throughout the month of November, the Centers for Medicare & Medicaid Services (CMS) issued a series of sub-regulatory guidance and accompanying resources to support states’ compliance with federal Medicaid and Children’s Health Insurance Program (CHIP) application and renewal requirements. The suite of guidance lays out federal requirements and various state options, and offers illustrative scenarios in anticipation of state questions—particularly those related to verifying income and resource eligibility when using available data sources. The guidance and resources, described at a high-level below, can be found on CMS’s .  

• Future of Section 1902(e)(14) Waivers Guidance: On November 14, CMS released a (CIB) and accompanying on how states can elect to extend permanently (beyond the expiration date of June 30, 2025) many 1 that provide flexibility in how states conduct eligibility redeterminations for Medicaid and CHIP. In an effort to continue supporting state improvements to their eligibility and enrollment systems, CMS evaluated all Section 1902(e)(14) waivers to determine which could be implemented permanently through other federal authorities, given that Section 1902(e)(14) authority is time-limited. As a result, CMS has allowed states to continue permanently more than half of the unwinding-related Section 1902(e)(14) waivers. Notably, the flexibilities that had the on increasing rates of ex parte renewals2 and maintaining coverage for eligible individuals are now permanently available for states.
• Evidence of Renewal Compliance Guidance: On November 15, CMS issued a specifying the “evidence” that states must submit to CMS by December 31 as part of their post-unwinding . The compliance guidance comes in follow-up to CMS’s  on state compliance with federal renewal requirements, and CMS is requesting this evidence to verify state compliance with the federal standards, rather than relying solely on state assurances. CMS will evaluate state submissions and may request further supporting documentation on an as needed basis.
• Financial Eligibility Verification Guidance: On November 20, CMS issued a and an accompanying outlining state requirements and flexibilities for verifying financial eligibility. This guidance primarily focuses on verification requirements at application, though the November 26 guidance (see below) provides additional information on verification requirements during the ex parte renewal process.
• Ex Parte Renewal Guidance: On November 26, CMS issued a on the requirements for conducting eligibility renewals on an ex parte basis for Medicaid and CHIP enrollees (also see accompanying ). This new guidance focuses on state implementation of federal ex parte renewal requirements and offers new state flexibility designed to increase ex parte renewal rates.

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