States must be in full compliance with all of CMS' Medicaid renewal requirements by the end of 2026.
In an informational bulletin published Sept. 20, Daniel Tsai, deputy administrator and director of the Center for Medicaid and CHIP services, said states must submit action plans for their plan to comply with renewal requirements by the end of 2024.
During the Medicaid redetermination process, CMS warned states several times about their lack of compliance with federal renewal requirements. In April 2023, states began the process of redetermining Medicaid members' eligibility for the first time since 2020.
During the COVID-19 public health emergency, states were prohibited from removing any beneficiaries from Medicaid rolls, regardless of their eligibility for the program.
As of Sept. 12, at least 25.2 million people have been disenrolled from Medicaid, according to KFF. Of those, around 70% were disenrolled for procedural reasons, rather than being determined ineligible for Medicaid benefits.
Nearly every state had to implement some form of corrective action during the Medicaid redeterminations process, Mr. Tsai wrote in the bulletin.
"Because CMS identified areas of non-compliance with renewal requirements in nearly every state during unwinding, with many common areas of non-compliance across states, CMS believes a standardized process will support states to achieve compliance with all renewal requirements in the most timely and efficient manner," Mr. Tsai wrote.
Most states have finished their Medicaid renewal process. A few states will continue into 2025. Around 12.5 million Medicaid beneficiaries have yet to have their eligibility reviewed, according to KFF.
States will be required to demonstrate their compliance with several key federal Medicaid regulations, including:
- Attempting renewals on an ex parte, or automatic, basis before contacting beneficiaries for information
- Allowing beneficiaries 30 days to return required documents
- Transferring beneficiaries who are no longer eligible for Medicaid to other assistance programs for which they may qualify
States with compliance issues must submit an update on their progress towards compliance to CMS every six months, according to the bulletin.
If states do not meet the standards set out by CMS by the end of 2026, they "may face additional agency action based on CMS assessment of the state’s circumstances and the nature of the non-compliance," Mr. Tsai wrote.
CMS will issue updated guidance late in 2024 to provide clarity on renewal requirements, Mr. Tsai wrote