CMS Offers States Additional Guidance on End of PHE

The Centers for Medicare & Medicaid Services (CMS) issued additional guidance to support states following the end of the public health emergency (PHE). Specifically, the guidance focuses on protecting eligible beneficiaries from inappropriate coverage losses during the unwinding period. CMS is providing states with the option to request authority under section 1902(e)(14)(A) of the Social Security Act in limited circumstances and subject to CMS approval.

On August 5, CMS approved strategies including:

• Renewal for Individuals Based on Supplemental Nutritional Assistance Program (SNAP) Eligibility (Targeted SNAP Renewal);
• Ex Parte Renewal for Individuals with No Income and No Data Returned (Beneficiaries with No Income Renewal);
• Facilitating Renewal for Individuals with no Asset Verification System (AVS) Data Returned within a Reasonable Timeframe (Streamlined Asset Verification);
• Partnering with Managed Care Plans to Update Beneficiary Contact Information (MCO Beneficiary Contact Updates);
• Use of the National Change of Address Database (NCOA) and United States Postal Service (USPS) Returned Mail to Update Beneficiary Contact Information (NCOA and/or USPS Contact Updates);
• Extending Automatic Reenrollment into Medicaid Managed Care Plans up to 120 Days (MCO Plan Auto-Reenrollment);
• Extended Timeframe to Take Final Administrative Action on Fair Hearing Requests (Fair Hearing Timeframe Extension); and
• Delaying the Resumption of Premiums Until a Full Redetermination is Completed (Premium Resumption Delay).

The Biden administration has stated that it would give at least sixty (60) days’ notice prior to the termination of the PHE declaration. With no official notice provided yesterday, it is expected that HHS Secretary Xavier Becerra will likely sign another extension on October 15.