On November 15, 2023, the Centers for Medicare & Medicaid Services released its proposed 2025 Notice of Benefit and Payment Parameters, the annual regulation which governs core provisions of the Affordable Care Act. This expert perspective focuses on aspects of the proposed rule likely to be of interest to state officials, including requirements for State-Based Marketplaces to align with the standards of the Federally Facilitated Marketplace, proposals for states to update essential health benefits, and initiatives to ease the eligibility and enrollment process for consumers.
Preparing to Implement the 12-Month Continuous Enrollment for Children Requirement
On Thursday, November 16, State Health and Value Strategies hosted a webinar on provisions included in the Consolidated Appropriations Act, 2023 (CAA) that require states to provide children up to age 19 with 12 months of continuous enrollment (CE) in Medicaid and the Children’s Health Insurance Program (CHIP) starting January 1, 2024.
During the webinar, experts from Manatt Health reviewed recent sub-regulatory guidance from CMS and considerations for states as they prepare to newly take up CE for children or modify existing CE policies to meet the CAA requirement. Presenters discussed the intersection of CE and renewal processes (particularly during the unwinding period), reviewed implications of CE for specific populations—including children in carceral settings and pregnant individuals—and highlighted more expansive state efforts to provide multi-year CE (most commonly for younger children) through section 1115 demonstration authority.