CMS Issues Guidance on Medicaid Continuous Enrollment

On January 5, the Centers for Medicare and Medicaid Services (CMS) released an informational bulletin regarding the unwinding of the Medicaid continuous enrollment and temporary federal match (FMAP) increase provisions that will no longer be linked to the end of the COVID-19 Public Health Emergency (PHE). The unwinding from the PHE was set out in the Consolidated Appropriations Act, 2023 (CAA), which was passed by Congress in December.

The provisions included in the CAA allow states to begin Medicaid eligibility redeterminations and renewals as of April 1, 2023, regardless of whether the COVID-19 PHE has ended. The law dictates that the increased FMAP must be decreased over time from its current 6.2% increase to a 5% increase (April 1 through June 30), then to a 2.5% increase (July 1 through September 30), and finally to a 1.5% increase (October 1 through December 31) before phasing out completely.

Highlights from the CMS guidance are below:

• Beginning April 1, 2023, states will be able to terminate Medicaid enrollment for individuals no longer eligible.
• Consistent with earlier guidance from CMS, the new March 31, 2023 statutory end date of the continuous enrollment condition means that states could begin their 12-month unwinding period and initiate the first Medicaid renewals that may result in disenrollment as early as February 1, 2023.
• Beginning April 1, 2023, states will be required to adhere to certain reporting requirements, and states that fail to do so may be subject to a reduction in FMAP. CMS expects to issue guidance soon about new reporting requirements and how they intersect with the requirements described in previous unwinding guidance.