CMS to end Medicaid continuous eligibility waivers: 5 things to know

CMS will not approve any new waivers for states to allow continuous enrollment for Medicaid or CHIP beneficiaries longer than 12 months. 

CMS has “concerns about the appropriateness of providing continuous eligibility,” said Drew Snyder, deputy CMS administrator and director of the Center for Medicaid and CHIP services in a July 17 letter to states. 

The agency does not anticipate approving new waiver requests for continuous eligibility programs, or renewing existing waivers once they expire, Mr. Snyder wrote. 

Continuous coverage provisions are designed to address Medicaid “churn,” whereby recipients are disenrolled due to administrative hurdles or temporary income fluctuations. 

Here are five things to know: 

1. Currently, states must redetermine beneficiary eligibility once every 12 months, and when beneficiaries’ income, household size or other circumstances change. In 2024, legislation took effect requiring states to provide 12 months of continuous eligibility for children under 19.
   
   
2. The American Rescue Plan Act allowed states to choose to offer 12 months of continuous coverage for postpartum mothers. Most states have implemented the policy.
   
   
3. Some states have received waivers allowing children to be continuously eligible for Medicaid until age 6, and to extend 24 months of continuous coverage for older children. Some states have received waivers allowing up to 24 months of continuous coverage for some adults.
   
   
4. Extending continuous coverage means some individuals who no longer qualify for Medicaid will remain on the program, Mr. Snyder wrote. 
   
   “We are concerned that expanding continuous eligibility beyond statutory limits could divert critical resources and funding away from individuals whose eligibility meets the standards laid out under the statute and regulation,” he wrote.
   
   
5. CMS will not renew waivers for states with exceptions to continuous eligibility laws, Mr. Snyder wrote. These states must notify members about changes to their current period of eligibility, and when they will need to reverify their eligibility for Medicaid benefits.