State Medicaid agencies are preparing for the largest health coverage event since the implementation of the Affordable Care Act: the “unwinding” of the Medicaid continuous coverage guarantee that has been in place for the duration of the COVID-19 public health emergency and will end on March 31, 2023. As states begin the herculean task of redetermining eligibility for 91 million enrollees in Medicaid and the Children’s Health Insurance Program, they are readying their systems, staff and vendors that support Medicaid eligibility operations.

The Consolidated Appropriations Act, 2023 (CAA) provides enhanced federal funding to states to support unwinding, provided that they conduct eligibility redeterminations and renewals in compliance with federal regulatory requirements and meet certain additional conditions. States must comply with all CAA conditions or adopt CMS-approved mitigation strategies to receive the enhanced Federal Medical Assistance Percentage (FMAP).

In “Ensuring Compliance With Federal Renewal Requirements,” a state diagnostic assessment tool prepared for the Robert Wood Johnson Foundation’s State Health and Value Strategies program, Manatt Health provides a resource states can use to evaluate their compliance with federal regulatory requirements for conducting redeterminations and renewals. The tool aims to help states qualify for the sustained enhanced FMAP, avoid corrective action imposed by CMS, promote continuity of coverage and care during unwinding, and make long-term improvements to eligibility and enrollment infrastructure.

To download the full diagnostic assessment tool, click here.