Release of New E&E Guidance Related to Renewal Forms and Medicaid/Separate CHIP Transitions
Kaylee O’Connor and Kinda Serafi, Manatt Health
Following the November release of guidance to support states’ efforts to verify eligibility and conduct renewals in compliance with federal Medicaid and CHIP requirements, the Centers for Medicare & Medicaid Services (CMS) issued on December 20 two additional Center for Medicaid and CHIP Services Informational Bulletins (CIBs):
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Renewal Form Guidance: The CIB outlines requirements related to renewal forms that states provide to Medicaid and CHIP enrollees. CMS offers detailed guidance on the required elements of the renewal form (e.g., which information should be requested and prepopulated), and the required modalities and timelines associated with the renewal form. The appendix to the guidance also includes a checklist that states may refer to for the elements that should be included in their renewal forms.
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Medicaid and Separate CHIP Transitions Guidance: The CIB provides guidance to help state effectuate a requirement (established in CMS’ April 2024 Streamlining the Medicaid, Children’s Health Insurance Program, and Basic Health Program Application, Eligibility Determination, Enrollment, and Renewal Processes final rule) that states seamlessly transition eligible children between Medicaid and separate CHIP beginning June 3, 2024. With this guidance, CMS is also exercising enforcement discretion and will not require state compliance with the following requirements until June 3, 2026: (1) that states send combined notices when a Medicaid-enrolled child is determined eligible for separate CHIP (and vice versa) , and (2) that states transfer accounts of individuals who are procedurally disenrolled from Medicaid or CHIP to the Marketplace.