CMS sets Medicaid renewal compliance deadlines

The feds have set new deadlines for compliance with Medicaid renewal requirements given widespread enrollment concerns during the unwinding. 

In a new notice, the Centers for Medicare & Medicaid Services (CMS) set a deadline of Dec. 31, 2026, for state programs to be in compliance with "applicable requirements." States must submit a report identifying areas of non-compliance and steps to address those issues by Dec. 31 of this year, CMS said. 

All states are required to submit the assessment and plan, according to the notice. For those that have already identified compliance issues and have an arrangement with CMS to address them, they will also need to complete a new report and plan to avoid potential enforcement, the agency said. 

The redetermination process has largely been completed, but CMS is expressing concern about reports of significant disenrollments during the unwinding. 

In the notice, CMS noted that issues with compliance were widespread. In March 2023, CMS told 36 states that they needed to roll out mitigation strategies to avoid action from the agency. 

"Through data analysis, discussions with states, and ongoing review of available information on state policies and processes during unwinding, CMS has continued to assess states’ renewal compliance and require mitigations, as appropriate," according to the notice. "Nearly all states were required to implement at least one mitigation strategy during unwinding, including states that needed to reinstate beneficiaries or temporarily pause renewal processing to protect coverage for eligible individuals." 

The notice said that because the agency identified major issues with compliance, taking a more standardized approach to the unwinding may be necessary to address those challenges, making the process more "timely and efficient." 

A recent analysis from KFF estimated that more than 25 million people lost coverage as part of the redetermination process. However, despite these coverage losses, about 10 million people more nationally are enrolled in either Medicaid or the Children's Health Insurance Program compared to pre-pandemic levels.