Meetings & Presentations | Apr 3, 2023

Ensuring Compliance with Federal Renewal Requirements

Patricia Boozang, Kinda Serafi and Kaylee O’Connor, Manatt Health

The recently enacted Consolidated Appropriations Act, 2023 (CAA) provides enhanced federal funding to states to support unwinding, provided that they conduct eligibility redeterminations and renewals in compliance with federal regulatory requirements at 42 CFR § 435.916 and meet certain additional conditions. States that are not able to fully comply with federal regulatory renewal requirements may still access the enhanced federal match and/or avoid corrective action by adopting Centers for Medicare & Medicaid Services (CMS)-approved mitigation strategies.

State Health and Value Strategies hosted a working session for state officials responsible for unwinding the Medicaid continuous coverage guarantee, or for operationalizing, refining, and overseeing E&E processes, including redeterminations/renewals and systems changes. During the session, presenters (1) provided a brief overview of this diagnostic assessment tool that states can use to assess compliance with federal renewal requirements, (2) discussed common mitigation areas, such as the inability to conduct ex parte renewals for non-Modified Adjusted Gross Income (non-MAGI) enrollees, or no online renewal capabilities, and (3) offered mitigation strategies to correct non-compliance and promote continuity of coverage and care during the unwinding.