CMS Releases Bulletin on HCBS Coverage Renewal Requirements and Flexibilities

On August 19, 2024, the Centers for Medicare & Medicaid Services (CMS) issued a CMCS Informational Bulletin (CIB) to remind states of the federal requirements and available flexibilities for ensuring the continuity of coverage for individuals receiving home and community-based services (HCBS). This bulletin is a continuation of CMS’ efforts to minimize coverage gaps, particularly during and after the public health emergency unwinding process, and to ensure eligible individuals retain or are re-enrolled in Medicaid following procedural disenrollments.

Notable provisions include:

• Ex Parte Renewals: States are required to initiate the renewal process without needing additional information from the beneficiary.
• Pre-populated Renewal Forms: When eligibility cannot be renewed ex parte, states must send a pre-populated form requesting only the necessary information.
• Reasonable Timeframe: Beneficiaries must have a minimum of 30 days to return the renewal form, with multiple options available for submission.
• Comprehensive Eligibility Determination: All potential bases for Medicaid eligibility must be considered before terminating coverage.
• Advance Notice: Beneficiaries must receive at least 10 days’ notice and be informed of their fair hearing rights before any reduction in benefits or termination of coverage.
• Account Transfers: For those ineligible for Medicaid, their account must be transferred promptly to another insurance affordability program.
• Reconsideration Period: States must reconsider eligibility without requiring a new application if the renewal form is returned within 90 days after coverage termination.