CMS Enforcement of State Medicaid Renewal Requirements

In January 2023, we first informed you of state-level changes to Medicaid and the Children’s Health Insurance Program (CHIP) brought by the end of the COVID-19 public health emergency (PHE). These programs play a critical role in rural areas, where people are more likely to be uninsured and face challenges accessing health care. In brief, states received extra federal funding to allow beneficiaries to keep their coverage – known as continuous enrollment – for as long as the PHE declaration remained in place.  As of August 2023, more than 13 million people had their enrollment in Medicaid/CHIP coverage renewed, but more than 7 million were disenrolled.  In this interim final rule, the Centers for Medicare & Medicaid Services (CMS) detail new reporting requirements for states as they “unwind” continuous enrollment – that is, return to reviewing the eligibility status of individuals and families.  The new requirements specify that reports for certain metrics, such as the number of individuals disenrolled and information about transitions to coverage through state Health Insurance Marketplaces, be completed and submitted in a timely manner.  New enforcement actions include suspended disenrollments, civil money penalties, and a reduction in federal funding known as the Federal Medical Assistance Percentage.

Comment by February 2.

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