CMS Released Updated Guidance Related to Planning for the Resumption of Normal State Medicaid, Children’s Health Insurance Program (CHIP), and Basic Health Program (BHP) Operations Upon Conclusion of the COVID-19 Public Health Emergency
On August 13, CMS released a State Health Official (SHO) letter that is intended to assist states in their planning efforts to resume routine Medicaid, CHIP, and BHP operations for the eventual end of the COVID-19 public health emergency (PHE). Specifically, this SHO provides updated guidance that extends the timeframe for states to complete pending eligibility and enrollment work to up to 12 months after the PHE ends and requires states to complete a redetermination of eligibility after the PHE for all beneficiaries prior to taking any adverse action. This requirement is a departure from the earlier guidance that allowed states to terminate coverage at the end of the PHE if the individual had been found ineligible within six months of the end of the PHE. The updated unwinding guidance reiterates states’ obligations with respect to conducting full redeterminations and providing beneficiaries ample time to respond to requests for redeterminations. The guidance also encourages states to employ eligibility and enrollment strategies that promote continuity of coverage and reduce processing delays. The guidance did not indicate whether the federal PHE will be extended; HHS has previously indicated only that it expects to continue the PHE through the end of this year and will provide states with notice before terminating it. SHVS is continuing to examine the letter in detail and is exploring future programming to help states prepare for the end of the PHE. Stay tuned.