On January 27, 2023, the Centers for Medicare & Medicaid Services released a State Health Official (SHO) letter, “Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.” The SHO letter is the second in a series of guidance related to section 5131 of the Consolidated Appropriations Act, 2023 (CAA), which established a fixed end date for the Medicaid continuous coverage requirement, a gradual phase-down for the enhanced federal match, and new guardrails for mitigating coverage loss for individuals who continue to be eligible. This expert perspective reviews the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter.
Federal Requirements and State Flexibilities for Verifying Eligibility Criteria
Manatt Health Solutions – Deborah Bachrach and Kinda Serafi
The Affordable Care Act and the final Medicaid and Exchange regulations issued in March 2012 contemplate: real-time eligibility determinations; coordinated information technology eligibility systems across Insurance Affordability Programs; and, a simplified enrollment pathway for applicants that relies on electronic database verification coupled with self-attestation. States have a great deal of flexibility when establishing the income verification process for Medicaid/CHIP and the advance premium tax credits (APTC)/cost sharing reductions. This brief prepared by Manatt Health Solutions summarizes some of the key verification requirements, with an emphasis on financial eligibility. The chart in the brief summarizes federal requirements and areas for potential state flexibility when verifying eligibility for both Medicaid and APTCs.