DEPARTMENT OF HEALTH & HUMAN SERVICES 
Centers for Medicare & Medicaid Services 
7500 Security Boulevard, Mail Stop S2-26-12 
Baltimore, Maryland   21244-1850 
 
 
CMCS Informational Bulletin 
 
DATE: December 18, 2023  
 
FROM: Daniel Tsai, Deputy Administrator and Director, Center for Medicaid & CHIP Services  
 
SUBJECT: Ensuring Eligible Children Maintain Medicaid and Childrens Health 
Insurance Program Coverage  
   
The purpose of this CMCS Informational Bulletin (CIB) is to remind states about federal 
eligibility requirements and available flexibilities to promote continuity of coverage of children 
and youth enrolled in Medicaid and the Childrens Health Insurance Program (CHIP). As of 
March 2023, at the end of the Medicaid continuous enrollment condition, nearly 42 million 
children were enrolled in Medicaid and CHIP.1 Together, the programs provide health coverage 
to over half of all children in the United States (U.S.), including millions of children and youth 
with special health care needs. Medicaid and CHIP cover essential services and supports for 
children, including visits to the pediatrician, regular screenings, mental health care, childhood 
immunizations, and emergency care. In addition to better short-term health and well-being, 
Medicaid and CHIP coverage has also been shown to provide long-term health, educational, and 
economic gains for children. For example, in a recent analysis, the Congressional Budget Office 
(CBO) found that an additional year of Medicaid coverage in childhood would lead to improved 
labor outcomes in adulthood, including higher earnings.2  
 
It is crucial that states do all they can to protect childrens health coverage. The Consolidated 
Appropriations Act, 2023 (CAA, 2023) ended the Medicaid continuous enrollment condition on 
March 31, 2023, requiring states to, over time, complete full Medicaid renewals and disenroll 
and refer individuals to other sources of coverage if they are determined to no longer be eligible. 
This process is often referred to as unwinding. CMS is particularly concerned about children 
that are disenrolled for procedural or administrative reasons (e.g., missing renewal form 
information). Many of these children are likely still eligible for coverage otherwise.   
 
Since the beginning of the unwinding period, enrollment in Medicaid and CHIP among children 
has declined by 2.2 million. While some children may have transitioned to other forms of health 
coverage, children have higher eligibility levels than adults, and it is likely that many children 
that have been disenrolled for procedural reasons or other administrative barriers are still income 
eligible for Medicaid and CHIP coverage. This may have devastating effects on childrens health 
and well-being.  
 
1 CMS, March 2023 Medicaid and CHIP Enrollment Data Highlights, July 2023, available at 
https://www.medicaid.gov/medicaid/program-information/medicaid-and-chip-enrollment-data/report-highlights/index.html.  
2 Congressional Budget Office, Exploring the Effects of Medicaid During Childhood on the Economy and the Budget: Working 
Paper 2023-27, November 1, 2023, available at https://www.cbo.gov/publication/59231  Page 2  CMCS Informational Bulletin 
 
States have the opportunity to adopt strategies that reduce red tape to help keep eligible children 
covered. The Centers for Medicare & Medicaid Services (CMS) is calling upon all states to 
redouble their efforts to implement policies and operational processes, conduct enhanced 
outreach, adopt all available waivers and flexibilities, and monitor data to ensure children who 
remain eligible for Medicaid and CHIP do not lose coverage.  
 
   
 
 
  Page 3  CMCS Informational Bulletin 
Executive Summary 
 
This CIB outlines federal renewal requirements and offers additional, actionable strategies that 
states can adopt to promote continuous coverage for children and youth who are likely eligible in 
Medicaid and CHIP. Key takeaways, described in further detail in the pages following, are: 
 
  Federal Renewal Requirements.  
  States are required to conduct redeterminations of eligibility for all individuals 
o
enrolled in Medicaid and CHIP in compliance with federal requirements. States 
must first attempt to renew eligibility for all Medicaid Modified Adjusted Gross 
Income (MAGI) and non-MAGI and CHIP beneficiaries based on available data 
without requiring additional information from the individual (referred to as ex 
parte renewal). States must send a renewal form only if available information is 
insufficient to renew the individuals eligibility on an ex parte basis. States must 
conduct renewals at the individual level, including for children in families with 
mixed immigration and citizenship status. In many families, children may still be 
eligible even if parents no longer meet Medicaid eligibility criteria and are 
referred to Marketplace coverage.  
  States may not deny or delay a redetermination to an otherwise eligible 
o
individual, including individuals who were initially eligible for Medicaid or 
CHIP as deemed newborns, as long as the family is attempting to obtain a 
social security number (SSN) for the infant.  
  States may not delay a renewal for Medicaid and CHIP pending information 
o
needed to complete a redetermination or due to other requirements for another 
human services program (e.g., the Supplemental Nutrition Assistance Program 
(SNAP)).  
  Effective January 1, 2024, all states will be required to provide 12-month 
o
continuous eligibility for children in Medicaid and CHIP. 
 
  Children and Youth with Special Health Care Needs. States should identify children 
and youth with special health care needs and implement targeted outreach and 
education and operational renewal processes that help support families of these 
children and minimize coverage loss. This may include partnering with other entities 
that serve these youth and their families, deploying assisters, and leveraging Medicaid 
managed care plans to support renewals.  
 
  Supporting Seamless Transitions Across Programs. States must support seamless 
transitions across Medicaid and CHIP at renewal. Specifically, when a state reviews 
available data sources and finds that a Medicaid-enrolled child appears to be eligible 
for a separate CHIP, or a separate CHIP-enrolled child appears to be eligible for 
Medicaid, the state must send a renewal form and give the household an opportunity 
to refute the information. CMS urges states to rely on data obtained by the state 
Medicaid or separate CHIP agency during an ex parte review to make the eligibility 
determination in the other program and minimize potential gaps in coverage. This 
strategy helps to facilitate transitions between the Medicaid and CHIP programs, 
 
 
  Page 4  CMCS Informational Bulletin 
ensure continuous coverage for children, and avoid procedural terminations. CMS is 
concerned that in states that choose not to adopt this approach, children otherwise 
eligible for coverage are not successfully renewing their eligibility for Medicaid or 
CHIP. 
 Additional Strategies States Can Adopt to Promote Continuity of Coverage. States
should adopt available federal authorities and flexibilities to maximize Medicaid and
CHIP coverage retention for eligible individuals. Specifically, these strategies allow
states to:
Increase ex parte renewal rates by adopting Express Lane Eligibility for
o
children, and/or the Targeted Supplemental Nutrition Assistance Program
(SNAP)/Temporary Assistance for Needy Families (TANF) Strategy, the
Beneficiaries with No Income Renewal Strategy, and the Beneficiaries with
Low Income Renewal Strategies for children and adults. (For additional
information and examples, see CMS Available State Strategies to Minimize
Terminations for Procedural Reasons During the COVID-19 Unwinding
Period).3 States with low ex-parte rates can also adopt additional strategies to
modify how they use available data to significantly increase the success rate of
ex-parte renewals, thereby keeping more eligible kids enrolled.
Strengthen outreach and renewal assistance by partnering with Medicaid
o
and CHIP managed care plans to share data on upcoming member renewals,
conduct targeted outreach and provide renewal assistance to families.
Maintain continuity of coverage by providing multi-year continuous
o
eligibility for children through section 1115 demonstration authority.
Maximize CHIP retention by eliminating or suspending premiums or
o
enrollment fees and removing premium lock-out periods. States can also
eliminate waiting periods and implement alternative strategies to monitor
substitution of coverage.
Increase retention by temporarily delaying or pausing procedural
o
disenrollments for beneficiaries for one or more months while the state conducts
targeted renewal outreach. This strategy allows beneficiaries who would
otherwise lose coverage for procedural reasons, such as failure to return a
renewal form, additional time to submit their renewal form or other necessary
information and provides states with additional time to conduct outreach.4
CMS recently granted waiver authority to two states to extend renewals for children for 
up to 12 months, to prevent procedural disenrollments of eligible children. Additional 
states interested in adopting this strategy are encouraged to contact CMS. Further, to 
support states efforts to establish and update income and eligibility determination 
systems that protect beneficiaries by maximizing states ability to ensure that eligible 
individuals retain coverage, CMS will extend all unwinding-related waivers provided 
3 CMS, Available State Strategies to Minimize Terminations for Procedural Reasons During the COVID-19 Unwinding Period, 
June 2023, available at https://www.medicaid.gov/sites/default/files/2023-06/state-strategies-to-prevent-procedural-
terminations.pdf.  
4 https://www.medicaid.gov/resources-for-states/coronavirus-disease-2019-covid-19/unwinding-and-returning-regular-
operations-after-covid-19/state-option-to-delay-procedural-disenrollments/index.html.   Page 5  CMCS Informational Bulletin 
under 1902(e)(14)(A) of the Act through December 31, 2024, unless later date has been 
approved by CMS. States may also continue to request new waiver authorities for 
implementation through December 31, 2024. CMS continues to assess the impact of 
these waivers to determine which may implemented under other authorities. Additional 
guidance on the continued availability of these strategies is forthcoming. 
 
  Outreach to Families and Strengthening Community Partnerships. State Medicaid and 
CHIP agencies are encouraged to collaborate with other family-facing state agencies and 
community partners, such as schools and community-based organizations, to ensure 
families have up-to-date information about the redetermination process, including what is 
required to keep eligible children enrolled in coverage. This may include working with 
schools to include messaging about Medicaid and CHIP renewals and engaging managed 
care plans.  
 
  Reporting and Monitoring. States are required to submit monthly reports to demonstrate 
state progress towards restoring timely application processing and initiating and 
completing renewals of eligibility for all Medicaid and CHIP beneficiaries. In addition to 
these unwinding-specific reports, states must also continue to meet existing monthly 
reporting requirements, including submitting timely data through the Medicaid and CHIP 
Eligibility and Enrollment Performance Indicator (Performance Indicator) dataset and 
data submissions through the Transformed Medicaid Statistical Information System (T-
MSIS) dataset. States are also encouraged to supplement their federal reporting with their 
own state-specific data analysis.  
 
CMS is supporting states by making flexibilities available to reduce coverage loss for eligible 
children and offering policy and operational technical assistance. CMS is also monitoring states 
activities to ensure that children have access to the coverage and care they need during the 
Medicaid unwinding period and beyond. CMS will continue to use the enforcement and 
oversight levers at its disposal to ensure state compliance with federal requirements (and 
implement approved mitigation strategies when out of compliance) intended to protect eligible 
children from losing coverage.  
   
 
 
  Page 6  CMCS Informational Bulletin 
CMCS Informational Bulletin 
 
Ensuring Eligible Children Maintain Medicaid and Childrens Health Insurance Program 
Coverage During the Unwinding Period and Beyond 
 
 
Table of Contents 
 
I.  Federal Renewal Requirements...................................................................................... 7
a.  Children in Families with Mixed Immigration and Citizenship Status .............................. 9
b.  Deemed Newborns ........................................................................................................ 9
II.  Children and Youth with Special Health Care Needs .................................................. 10
III. Supporting Seamless Transitions Across Programs ..................................................... 11
IV. Additional Strategies to Promote Continuity of Coverage ........................................... 12
a.  Leveraging Section 1902(e)(14)(A) Waivers ................................................................. 12
b.  Partnering with Managed Care Plans .......................................................................... 13
c.  Providing Continuous Eligibility for Children .............................................................. 14
d.  Implementing Express Lane Eligibility ......................................................................... 14
e.  Modifying CHIP Premium Policies .............................................................................. 14
f.  Modifying Policies for Substitution of Coverage in Separate CHIP ............................... 15
g.  Delaying Procedural Disenrollments for Children to Enhance Outreach....................... 16
V.  Messaging to Families and Strengthening Community Partnerships .......................... 16
VI. Reporting and Monitoring............................................................................................ 17
VII. Closing .......................................................................................................................... 19
 
 
  Page 7  CMCS Informational Bulletin 
I.  Federal Renewal Requirements 
 
States are required to conduct redeterminations of eligibility for all individuals enrolled in 
Medicaid and CHIP in compliance with federal requirements at 42 C.F.R.  435.916 and 
457.343 and as outlined in the CIB, Medicaid and Childrens Health Insurance Program (CHIP) 
Renewal Requirements.5 While this informational bulletin provides a general overview of the 
renewal requirements, states should refer to the federal requirements at 42 C.F.R.  435.916 and 
457.343 and the CIB, Medicaid and Childrens Health Insurance Program (CHIP) Renewal 
Requirements, for a complete understanding of the renewal requirements.  CMS is also 
available to provide technical assistance to states. 
 
At renewal, states are required to first attempt to renew eligibility for all MAGI and non-MAGI 
Medicaid and CHIP beneficiaries based on reliable information available to the state agency 
without requiring information from the individual.6 Such renewals are referred to as ex parte 
renewals.7 If the agency is able to renew eligibility based on available reliable information, the 
agency must provide notice of the determination and basis for eligibility,8 and the individual may 
not be required to sign and return the notice if all information is accurate.9 If information is 
insufficient to renew or redetermine eligibility on an ex parte basis, the state Medicaid agency 
must send a renewal form and request only the information necessary to redetermine eligibility.10 
Renewal forms must be prepopulated for MAGI-based Medicaid and CHIP beneficiaries, and 
states are encouraged to use prepopulated renewal forms at their option for non-MAGI Medicaid 
beneficiaries.11 The agency is encouraged to provide a prepopulated renewal form for non-MAGI 
beneficiaries.12 States must provide MAGI beneficiaries a minimum of 30 days to return the 
prepopulated renewal form and any requested information;13 non-MAGI beneficiaries must be 
provided with a reasonable period of time to return their renewal form and any required 
information.14 The agency must provide clear instructions for all beneficiaries on how to 
complete the form and correct any inaccurate prepopulated information, how the form and other 
documentation can be returned, and the timeframe in which the individual must respond.15 
Renewal forms and notices must be accessible to individuals with limited English proficiency 
and persons with disabilities.16 The agency must continue to furnish Medicaid to beneficiaries 
who have returned their renewal form and all requested documentation unless and until they are 
determined to be ineligible.17 States may not delay a renewal for Medicaid and CHIP pending 
 
5 42 C.F.R.  435.916; CMS, CIB, Medicaid and Childrens Health Insurance Program (CHIP) Renewal Requirements, 
December 4, 2020, available at https://www.medicaid.gov/federal-policy-guidance/downloads/cib120420.pdf.  
6 42 C.F.R.  435.916 (a)(2) and (b) and  457.343. 
7 An ex parte renewal is sometimes referred to as auto renewal, passive renewal, or administrative renewal. 
8 Notice must be provided consistent with 42 C.F.R.  435.917, Part 431, subpart E, and 457.340(e), as applicable. 
9 42 C.F.R.  435.916(a)(2)(i) and (ii) and 435.916(b), 435.917, and 457.343. 
10 42 C.F.R.  435.916(a)(3), 435.916(b), 435.916(e), and 457.343. 
11 42 C.F.R.  435.916(a)(3)(i)(A) and 457.343. 
12 42 C.F.R.  435.916(b). 
13 42 C.F.R.  435.916(a)(3)(i)(B) and 457.343. 
14 42 C.F.R.  435.952. 
15 42 C.F.R.  435.905(b) and 457.340; CMS, CIB, Medicaid and Childrens Health Insurance Program (CHIP) Renewal 
Requirements, December 4, 2020, available at https://www.medicaid.gov/federal-policy-guidance/downloads/cib120420.pdf.  
16 42 C.F.R.  435.916(g).  
17 42 C.F.R.  435.930(b). 
 
 
  Page 8  CMCS Informational Bulletin 
information needed to complete a redetermination or other requirements for another human 
services program (e.g., the Supplemental Nutrition Assistance Program (SNAP)). 
 
States must determine and redetermine Medicaid and CHIP eligibility on an individual basis.18 
When multiple members of a household are enrolled in Medicaid or CHIP, the state may process 
renewals for an entire household or multiple members of a household at the same time if their 
eligibility periods are aligned. However, the state must conduct the renewal for each individual 
consistent with 42 C.F.R.  435.916 and 457.343, including renewing eligibility on an ex parte 
basis for each individual in the household, if able to do so, and only requesting information 
necessary to redetermine eligibility for those individuals who the state cannot redetermine on an 
ex parte basis.  
 
Income and other eligibility requirements vary by eligibility group in Medicaid and CHIP, and 
eligibility levels for children are generally higher than those for adults. As a result, at renewal, 
even when a parent or guardian is no longer eligible for Medicaid, a child may remain eligible, 
due to higher income limits. The median upper income limit for children in Medicaid and CHIP 
is 255 percent of the federal poverty level (FPL) compared to 133 percent of the FPL for adults. 
Nearly all states have established childrens eligibility levels for Medicaid-expansion or separate 
CHIP programs at or above 200 percent of the FPL.  
 
In instances where states are unable to renew eligibility for a parent or guardian on an ex parte 
basis, states must still renew eligibility on an ex parte basis for children or other members of the 
household for whom the state has sufficient information to determine continued eligibility. States 
may only request information needed to determine eligibility for those family members for 
whom the state does not have sufficient information to renew eligibility on an ex parte basis. 
States may not require household members whose eligibility may be renewed on an ex parte 
basis to return a renewal form simply because the state must provide another member of the 
household a renewal form. For additional information and examples, see CMS State Medicaid 
Director Letter (SMDL), Ensuring Compliance with Requirements to Conduct Medicaid and 
CHIP Renewal Requirements at the Individual Level, Attachment B.19 
 
 
Important reminders for conducting redeterminations of eligibility at the individual level for 
Medicaid- and CHIP-enrolled children:  
  States must determine and redetermine Medicaid and CHIP eligibility on an individual 
basis, including for children in households with at least one adult enrolled in Medicaid 
and for children in families with mixed immigration and citizenship status.  
  In instances where states are unable to renew eligibility for a parent or guardian on an 
ex parte basis, states must still renew eligibility on an ex parte basis for children for 
whom the state has sufficient information to determine continued eligibility. 
 
18 42 C.F.R.  435.911(c), 435.926, 457.343, and 457.350(b)(1). 
19 CMS, SMDL, Ensuring Compliance with Requirements to Conduct Medicaid and CHIP Renewal Requirements at the 
Individual Level, August 30, 2023, available at https://www.medicaid.gov/media/162301, and  5112 of the Consolidated 
Appropriations Act, 2023 (CAA, 2023) (P.L 117-328 ), available at https://www.congress.gov/117/bills/hr2617/BILLS-
117hr2617enr.pdf.  
 
 
  Page 9  CMCS Informational Bulletin 
  States may not require household members whose eligibility may be renewed on an ex 
parte basis to return a renewal form simply because the state must provide another 
member of the household a renewal form. 
 
 
a.  Children in Families with Mixed Immigration and Citizenship Status  
In some cases, children are eligible for Medicaid or CHIP even if their parents are ineligible due 
to their immigration or citizenship status, and the immigration or citizenship status of a parent 
should not preclude an eligible child from enrolling in or maintaining Medicaid or CHIP. 
Individuals may apply for Medicaid, CHIP, or Marketplace coverage on behalf of their family 
members, regardless of their own eligibility statuses.20 States must ensure that eligibility is 
determined separately for each member of the household and that inability to verify immigration 
status for one or more household members does not impede the initial eligibility determination or 
ability for a state to complete a renewal, including on an ex parte basis, for another household 
member.21 
 
For individuals, including children, enrolled in Medicaid, state Medicaid agencies may not 
reverify citizenship at renewal, unless the individual reports a change in citizenship or the agency 
has received information indicating a potential change in the individual's citizenship.22 Similarly, 
an individuals immigration status does not need to be reverified if it is not likely to change (e.g., 
Lawful Permanent Resident status) unless the individual reports such a change has occurred.23 
 
b.  Deemed Newborns 
States must deem infants born to pregnant individuals who are eligible for and received covered 
services in Medicaid or CHIP as continuously eligible from birth until the childs first birthday 
without requiring an application.24 When the infant who was deemed Medicaid or CHIP eligible 
at birth is due for renewal after the first year, states must first attempt an ex parte renewal prior 
to requesting additional information, if needed,  and may not require the family to reapply for the 
infant to retain coverage. Individuals who were initially eligible for Medicaid or CHIP as 
deemed newborns are considered to have provided satisfactory documentation of citizenship 
and identity (by virtue of being born in the U.S.) and are not required to further document 
citizenship or nationality in any subsequent Medicaid or CHIP redetermination.25 States must 
assist families with applying for an SSN if they do not have one or with verifying an SSN if they 
cannot recall the number.26 An agency may not deny or delay a redetermination to an otherwise 
 
20 United States Department of Health and Human Services, Health Coverage Options for Immigrants, July 2022, available at 
https://www.hhs.gov/guidance/sites/default/files/hhs-guidance-documents/Health-Coverage-Options-Immigrants-2022.pdf.  
21 42 C.F.R.  435.911. 
22 42 C.F.R.  435.956(a)(4). 
23 CMS, CIB, Medicaid and Childrens Health Insurance Program (CHIP) Renewal Requirements, December 4, 2020, available 
at https://www.medicaid.gov/federal-policy-guidance/downloads/cib120420.pdf. 
24 Section 1902(e)(4) and 2112(e) of the Act; 42 C.F.R.  435.117 and 457.360. In CHIP, states must provide deemed newborn 
coverage to children born to pregnant individuals who were eligible for CHIP coverage as targeted low-income pregnant 
women. States may also elect to provide deemed newborns coverage for infants born to pregnant targeted low-income children.  
25 Section 1903(x)(2)(D) of the Act. 
26 42 C.F.R.  435.910(e), 435.956, and 457.340(b). 
 
 
  Page 10  CMCS Informational Bulletin 
eligible individual pending issuance or verification of the SSN, as long as the family is 
attempting to obtain an SSN for the infant.27  
 
II.  Children and Youth with Special Health Care Needs 
Medicaid covers more than one-third (36.6 percent) of children and youth with special health 
care needs, and these youth may depend on Medicaid and CHIP daily for life-sustaining 
treatment, including medications, durable medical equipment, home care, and medical care.28 
States should consider deploying strategies specifically focused on mitigating coverage loss for 
children and youth with special health care needs (CYSHN)29.  
 
Identifying CYSHN enables Medicaid and CHIP agencies to better support retention of eligible 
high-risk individuals during renewal and on an ongoing basis. States can identify CYSHN in a 
number of ways, including based on:  
  Eligibility group, including children and youth enrolled in eligibility categories for 
individuals with disabilities, or former foster care youth;  
  Receipt of specialized or high-risk care for physical or behavioral health needs, including 
through state plan benefits (such as targeted case management or health homes), 
demonstration projects under section 1115 of the Social Security Act (the Act), home and 
community-based services waivers; and  
  Claims and encounter data to identify children and youth in an active course of treatment 
for a complex illness (e.g., children or youth receiving cancer treatment). 
 
To minimize loss of coverage and promote continuity of care for eligible children, state agencies 
are strongly encouraged to: 
  Partner with other entities, including Title V and other state programs providing support 
to CYSHCN and their families, to ensure that those entities have clear information to 
support families through the redetermination process; 
  Adopt special redetermination processes, such as providing longer timeframes for 
individuals to respond to requests for information to complete the renewal process, 
following up with multiple outreaches through alternate modalities for beneficiaries who 
do not respond to renewal forms and requests for additional information, and/or offering 
enhanced outreach and renewal assistance through state or regional eligibility offices; 
  Require Medicaid managed care plans to conduct targeted assistance with completing 
renewals; and  
  Fund Navigators and/or application assisters or embed assisters into settings with high 
volumes of beneficiaries who are CYSHCN to facilitate renewals and/or seamless 
transitions to other coverage. 
 
 
27 42 C.F.R.  435.910(f), 435.956, and 457.340(b). 
28 Medicaid and CHIP Payment and Access Commission, Medicaid Access in Brief: Children and Youth  
with Special Health Care Needs, March 2023, available at https://www.macpac.gov/wp-content/uploads/2023/03/Medicaid-
Access-in-Brief-Children-and-Youth-with-Special-Health-Care-Needs.pdf,  
29 CMS, Medicaid Unwinding: An All-Hands-On-Deck Strategy to Support Outreach to Children and Families, August 2023, 
available at https://www.medicaid.gov/media/161661. 
 
 
  Page 11  CMCS Informational Bulletin 
III.  Supporting Seamless Transitions Across Programs  
Medicaid and CHIP agencies must have renewal processes in place that ensure children who are 
no longer eligible can seamlessly transition between coverage programs. If a state Medicaid 
agency determines that an individual is ineligible for full-benefit Medicaid coverage under all 
bases, it must determine potential eligibility for other insurance affordability programs (e.g., 
separate CHIP or Marketplace coverage) and transfer that individuals electronic account to such 
program, as appropriate.30 Similarly, if a state determines that a separate CHIP beneficiary is no 
longer eligible, it must screen the individual for eligibility in other insurance affordability 
programs, including Medicaid (on all bases) and Marketplace coverage.31 If the child is 
determined potentially eligible for another coverage program, the state must transfer the childs 
account to that program.32 
 
At renewal, when a state reviews available data sources and finds that a Medicaid-enrolled child 
appears to be eligible for a separate CHIP, or a separate CHIP-enrolled child appears to be 
eligible for Medicaid, the state must send a renewal form and give the household an opportunity 
to refute the information.33 If the family does not return the form, the state should complete an 
eligibility determination based on available information and enroll the child in the other program 
for which such information indicates they are eligible. States must maintain the child in the 
current coverage program prior to executing any adverse action (i.e., terminating coverage under 
either program).   
 
As described in CMS guidance on Supporting Seamless Coverage Transitions for Children 
Moving Between Medicaid and CHIP in Separate CHIP States, data obtained by the state 
Medicaid or separate CHIP agency during an ex parte review may be used to make the eligibility 
determination in the other program.34 This helps to facilitate transitions between Medicaid and 
CHIP to ensure continuous coverage for children and avoid procedural terminations when the 
state finds the child eligible using available and reliable data.  
 
 
In order to mitigate coverage loss for eligible children transitioning between coverage 
programs if a family does not respond to a renewal form, CMS recommends that :  
(1) Medicaid agencies use the data obtained by CHIP during the ex parte review to 
make a determination of eligibility and enroll the child in Medicaid (if eligible) 
without requesting additional information to confirm Medicaid eligibility; and  
(2) CHIP agencies use the data obtained by the Medicaid agency during the ex parte 
review to make a determination of eligibility and enroll the child in CHIP without 
requesting additional information to confirm CHIP eligibility. 
 
 
 
30 42 C.F.R.  435.916(f).  
31 42 C.F.R.  457.350(b). 
32 42 C.F.R.  435.1200(e)(1) and 457.351 
33 42 C.F.R.  435.916 and 457.343. 
34 CMS, Supporting Seamless Coverage Transitions for Children Moving Between Medicaid and CHIP in Separate CHIP 
States, December 12, 2022, available at https://www.medicaid.gov/resources-for-states/downloads/supporting-medicaid-chip-
transitions.pdf.  
 
 
  Page 12  CMCS Informational Bulletin 
For children whose household income is above CHIP eligibility levels, states are required to 
seamlessly transfer the childs account to a Basic Health Program, the Federally-Facilitated or 
State-Based Marketplace (whichever is applicable) for a determination of eligibility.35 
 
IV.  Additional Strategies to Promote Continuity of Coverage 
States are encouraged to adopt available federal authorities and flexibilities to maximize 
retention in Medicaid and CHIP and help ensure smooth transitions to other health care coverage 
for children leaving the programs. Strategies that may ensure continuity of coverage among 
children are detailed below.  
 
a.  Leveraging Section 1902(e)(14)(A) Waivers  
To support states in their efforts to successfully resume normal eligibility and enrollment 
operations following the end of the Medicaid continuous enrollment condition, CMS has made 
available a number of authorities under Section 1902(e)(14)(A) of the Act.36 Section 
1902(e)(14)(A) of the Act, added by Section 2002 of the Affordable Care Act, allows for waivers 
as are necessary to ensure that states establish income and eligibility determination systems that 
protect beneficiaries. To support states efforts to establish and update income and eligibility 
determination systems that protect beneficiaries by maximizing states ability to ensure that 
eligible individuals retain coverage, CMS will extend all unwinding-related waivers provided 
under 1902(e)(14)(A) of the Act through December 31, 2024, unless a later date has been 
approved by CMS. States may also continue to request new waiver authorities for 
implementation through December 31, 2024. CMS continues to assess the impact of these 
waivers to determine which may implemented under other authorities. Additional guidance on 
the continued availability of these strategies is forthcoming. 
 
Several section 1902(e)(14)(A) strategies can help states increase ex parte rates and enhance the 
ex parte process for children and youth, in effect minimizing loss of coverage. Since ex parte 
renewals rely on verifying eligibility using available and reliable information, the renewal can be 
completed without requiring the beneficiary to return a renewal form or provide other 
information and/or documentation. As such, the risk of coverage loss for procedural reasons 
among beneficiaries who meet the substantive eligibility criteria is significantly reduced.  
 
 
Examples of strategies authorized using waiver authority under section 1902(e)(14)(A) 
strategies that enhance the ex parte process and reduce risk of procedural terminations for 
eligible children and other beneficiaries include but are not limited to:  
  Targeted SNAP/TANF Strategy, which allows states to renew Medicaid eligibility 
based on financial findings from SNAP, TANF, or other means-tested programs. This 
flexibility can also be applied to CHIP in states where the SNAP or other means-tested 
program eligibility levels are higher than the Medicaid level and below the CHIP 
levels. 
 
35 42 C.F.R  457.350. 
36 CMS, COVID-19 PHE Unwinding Section 1902(e)(14)(A) Waiver Approvals, October 2023, available at 
https://www.medicaid.gov/resources-for-states/coronavirus-disease-2019-covid-19/unwinding-and-returning-regular-operations-
after-covid-19/covid-19-phe-unwinding-section-1902e14a-waiver-approvals/index.html.  
 
 
  Page 13  CMCS Informational Bulletin 
  Beneficiaries with No Income Renewal Strategy, which allows states to renew 
eligibility on an ex parte basis for MAGI and non-MAGI individuals with $0 income 
when no data is returned. 
  Beneficiaries with Low Income Renewal Strategy, which allows states to renew 
eligibility on an ex parte basis for MAGI and non-MAGI individuals with income at 
or below 100 percent of the FPL when no data is returned. This strategy helps reduce 
the administrative burden on families and the state, particularly when verifying 
complex self-employment income. 
 
CMS also recently granted waiver authority to two states to extend renewals for children for 
up to 12 months, to support retention for children, conduct outreach, and minimize procedural 
disenrollments of eligible individuals. Other states interested in adopting this strategy are 
encouraged to contact CMS.  
 
As of December 2023, CMS has approved nearly 400 waivers under section 1902(e)(14) of the 
Act, but there are many more strategies that states may adopt. States may request authority to 
implement one or more of these strategies by contacting their CMS state lead. CMS is available 
to provide technical assistance and can provide sample language the state can use to craft a letter 
requesting the waiver authority. 
 
b.  Partnering with Managed Care Plans 
States that deliver services through Medicaid and CHIP managed care should consider 
partnering with managed care plans to support coverage retention, particularly for children 
enrolled in managed care. States are strongly encouraged to work with managed care plans for 
targeted outreach. States may send lists to managed care plans of individuals who are due for 
renewal in order for the plans to conduct outreach to remind parents/guardians to respond to 
renewal packets. In addition, states may utilize managed care plans to conduct additional 
outreach to families who lost coverage for procedural reasons, so that families may return their 
renewal form to have their eligibility reconsidered. Managed care plans can also utilize multiple 
modalities to reach families (e.g., phone call, email, text). States should have managed care 
plans partner with pediatricians and other childrens providers to support coverage retention and 
work with families to maintain enrollment. 
 
 
During unwinding, states also have expanded opportunities to work with managed care plans 
using strategies authorized using waiver authority under section 1902(e)(14)(A) of the Act to:  
  Accept updated beneficiary contact information provided by managed care plans 
without taking an additional step to verify the new information; and 
  Direct managed care plans to provide assistance to parents/guardians and their 
households to complete Medicaid and CHIP renewal forms. 
 
 
For more information on how states may work with managed care organizations, states can 
review CMS Strategic Approaches to Engaging Managed Care Plans to Maximize Continuity 
 
 
  Page 14  CMCS Informational Bulletin 
of Coverage as States Resume Normal Eligibility and Enrollment Operations.37 
 
c.  Providing Continuous Eligibility for Children  
Pursuant to the CAA, 2023, beginning January 1, 2024, all states will be required to provide 
children enrolled in Medicaid and CHIP with 12 months of continuous eligibility, even if the 
family experiences a change in circumstances during the year that would otherwise impact the 
childs eligibility, such as a change in income or household size.38 Continuous eligibility 
promotes continuity of coverage and helps provide children consistent access to needed health 
care services.39 For additional information, see CMS State Health Official Letter (SHO) #23-
004, Section 5112 Requirement for all States to Provide Continuous Eligibility to Children in 
Medicaid and CHIP under the Consolidated Appropriations Act, 2023.40   
 
To further strengthen continuity of coverage for children, states also may consider providing 
multi-year continuous eligibility for children (e.g., continuous eligibility up to age six, 24 
months of continuous eligibility) through Section 1115 demonstration authority.41   
 
d.  Implementing Express Lane Eligibility 
To streamline enrollment and renewals for children, states should consider adopting the Express 
Lane Eligibility state plan option described at sections 1902(e)(13) and 2107(e)(1) of the Act. 
The Express Lane Eligibility option permits states to rely on findings (including related to 
income) from an entity designated by the state as an Express Lane Agency to determine a childs 
eligibility for Medicaid or CHIP.42  States may use this option when determining eligibility for 
children at application and/or renewal. To adopt this option, states must submit a SPA.43  
 
e.  Modifying CHIP Premium Policies 
Research has shown that roughly one in five children experience a gap in coverage when 
transitioning from Medicaid to CHIP, and premiums are a known barrier both to enrollment and 
seamless transitions. 44 To mitigate loss of coverage among children due to failure to pay 
 
37 CMS, Strategic Approaches to Engaging Managed Care Plans to Maximize Continuity of Coverage as States Resume Normal 
Eligibility and Enrollment Operations, January 2023, available at  https://www.medicaid.gov/resources-for-
states/downloads/health-plan-strategy.pdf. 
38 Section 5112 of the CAA (P.L 117-328), available at https://www.congress.gov/117/bills/hr2617/BILLS-117hr2617enr.pdf.  
39 ASPE, Medicaid Churning and Continuity of Care: Evidence and Policy Considerations Before and After the COVID-19 
Pandemic, April 12, 2021, available at https://aspe.hhs.gov/sites/default/files/private/pdf/265366/medicaid-churning-ib.pdf.  
40 CMS, SHO #23-004, Section 5112 Requirement for all States to Provide Continuous Eligibility to Children in Medicaid and 
CHIP under the Consolidated Appropriations Act, 2023, September 29, 2023, available at 
https://www.medicaid.gov/sites/default/files/2023-09/sho23004.pdf.  
41 See for example, CMS Demonstration Approval Letter, Oregon Health Plan, September 28, 2022, available at 
https://www.oregon.gov/oha/HSD/Medicaid-Policy/Documents/2022-2027-1115-Demonstration-Approval.pdf, and CMS 
Demonstration Approval Letter, Washington Medicaid Transformation Project, April 14, 2023, available at 
https://www.medicaid.gov/medicaid/section-1115-demonstrations/downloads/wa-stc-ca-04142023.pdf.  
42 Express Lane Agencies may include SNAP, TANF, School Lunch, Head Start, National School Lunch Program, and Women, 
Infants, and Children, among others. For more information see, CMS, Opportunities to Support Unwinding Efforts for States 
with Integrated Eligibility Systems and/or Workforces, September 2022, available at https://www.medicaid.gov/resources-for-
states/downloads/opp-unwind-eff-st-integ-elig-sys-workforce.pdf. 
43 For more information on Express Lane Eligibility and SPA templates, see CMS SHO #10-003, Express Lane Eligibility 
Option, February 2010, available at https://www.medicaid.gov/sites/default/files/Federal-Policy-
Guidance/downloads/SHO10003.PDF.  
44 Medicaid and CHIP Payment and Access Commission, Updated Analysis of Churn and Coverage Transitions, April 7, 2022, 
available at https://www.macpac.gov/publication/updated-analyses-of-churn-and-coverage-transitions/. 
 
 
  Page 15  CMCS Informational Bulletin 
monthly premiums, states may elect to permanently eliminate or temporarily suspend premiums 
during the unwinding period. In addition, CMS proposed rule published in September 2022 
proposed to eliminate premium lock-out periods.45 Premium lock-out periods have permitted 
states to specify a period of time that an individual must wait after non-payment of premiums 
until being allowed to reenroll in CHIP. Applicable states are encouraged to either eliminate 
premium lock-out periods permanently or suspend this policy during the unwinding period. CMS 
encourages states that are constrained in their ability to eliminate such cost-sharing to instead 
establish affordable annual enrollment fees rather than collecting monthly premium payments. 
Affordable enrollment fees encourage continued enrollment throughout the year and eliminate 
the possibility of disenrollment for failure to pay monthly premiums. Where states maintain 
premiums, to help prevent missed or late premium payments, states could deploy targeted 
outreach and enhanced notice strategies.  
 
Many states have a tiered premium structure based on a childs household income. Upon review 
of available data sources during an ex parte renewal, a state may find that a CHIP-enrolled child 
appears subject to either a higher or lower premium amount than their current premium band. 
Under these circumstances, states are strongly encouraged to adopt the following premium 
assignment principles:46 
  Lower Cost Premium Band: If available data shows the child is eligible for a lower cost 
premium band, the state should move the child to the lower cost premium band and send 
a notice to the household informing them of the change and the basis for the 
determination. No additional action is needed by the beneficiary.  
  Higher Cost Premium Band: If the available data shows the child may be subject to a 
higher cost premium band, the state should maintain the child in the same premium band 
and give the household an opportunity to refute the information that was obtained from 
data sources. If a beneficiary provides documentation/additional information in response 
to a request for information, the state should revise the premium band based on that 
documentation/information. If the beneficiary does not respond to the request for 
information, the state should not terminate coverage but rather assign the premium band 
based on the available data. 
 
f.  Modifying Policies for Substitution of Coverage in Separate CHIP 
Unlike Medicaid, separate CHIP requires children to be uninsured to be eligible for coverage,47 
except if a state elects to provide premium assistance through its separate CHIP.48 States with 
separate CHIPs are required to use reasonable methods to ensure that separate CHIP coverage is 
not substituting for group health plan coverage.49 One method some states use to implement this 
requirement is applying a waiting period, which is a period of uninsurance (not to exceed 90 
 
45 CMS, Proposed Rule: Streamlining the Medicaid, Childrens Health Insurance Program, and Basic Health Program 
Application, Eligibility Determination, Enrollment, and Renewal Processes,  September 7, 2022, available at: 
https://www.federalregister.gov/documents/2022/09/07/2022-18875/streamlining-the-medicaid-childrens-health-insurance-
program-and-basic-health-program-application.  
46 CMS, Supporting Seamless Coverage Transitions for Children Moving Between Medicaid and CHIP in Separate CHIP 
States, December 12, 2022, available at https://www.medicaid.gov/resources-for-states/downloads/supporting-medicaid-chip-
transitions.pdf. 
47 Section 2101(a) of the Act and 42 C.F.R.  457.1, 457.2 and 457.10.  
48 Section 2105(c)(10) of the Act. 
49 42 C.F.R.  457.805(a). 
 
 
  Page 16  CMCS Informational Bulletin 
days) after an individual has disenrolled from group health plan coverage, Medicaid, or CHIP 
before they can enroll/re-enroll in CHIP.50 CMS encourages states to eliminate such waiting 
periods to reduce potential barriers or delays for otherwise eligible children to enroll in CHIP. 
States may adopt alternative methods for addressing concerns about substitution of group health 
plan coverage, such as monitoring. Examples of common substitution monitoring strategies 
include adding questions to health coverage applications about enrollment in private coverage 
and conducting database checks to ensure CHIP beneficiaries do not have other coverage.   
 
g.  Delaying Procedural Disenrollments for Children to Enhance Outreach 
One of the key strategies offered by CMS is the state option to delay procedural disenrollments 
for beneficiaries for one or more months while the state conducts targeted renewal outreach. This 
strategy allows beneficiaries who would otherwise lose coverage for procedural reasons, such as 
failure to return a renewal form, additional time to complete their renewal form or provide other 
necessary information and gives states additional time to conduct outreach. This strategy can be 
targeted to specific populations at risk of losing coverage, including children. This strategy is 
available for states to implement throughout the unwinding period, or on an ad hoc basis for 
cohorts of renewals based on certain defined criteria (e.g., if the percent of anticipated procedural 
disenrollments exceeds a specified threshold). States must use the additional time to conduct 
targeted outreach to encourage beneficiaries to return renewal forms. 
 
States seeking to elect this strategy should request concurrence for an exception to timely 
determinations of eligibility per regulations at 42 C.F.R.  435.912(e). States interested in 
implementing this strategy should send an email requesting concurrence to the CMS unwinding 
mailbox (CMSUnwindingSupport@cms.hhs.gov) and note the use of this strategy in their 
unwinding plans. 
 
V.  Outreach to Families and Strengthening Community Partnerships 
Children may lose coverage if their parents or guardians believe they or their children no longer 
meet the eligibility requirements and do not respond to renewal forms and/or requests for 
information.  Families may not realize their children may still be eligible for coverage through 
Medicaid or CHIP due to higher income thresholds for children. In addition, families with young 
children enrolled in Medicaid and CHIP may have never had to complete a renewal before (e.g., 
if their child was a deemed newborn and/or if their child was enrolled just before or while the 
continuous enrollment condition was in effect).  
 
 
CMS encourages state Medicaid and CHIP agencies to collaborate with other state agencies 
and community partners to ensure families have up-to-date information about the 
redetermination processincluding what is required to keep children in coverage.  
 
State Medicaid and CHIP agencies can: 
 
50 42 C.F.R.  457.805(b)(2). 
 
 
  Page 17  CMCS Informational Bulletin 
  Encourage parents or guardians to fill out renewal forms for their children who cannot 
be renewed on an ex parte basis, even if the parents or guardians are no longer 
eligible.  
  Work with other family-facing state agencies to share up-to-date information about 
renewals, and request that they engage directly with families.  
  Promote consistent messaging by distributing communication materials, such as 
flyers, social media graphics, and articles. (Messages and materials specific to 
parents/guardians and children may be found on the CMS Communications Page).51 
  Engage community-based organizations to play a role in educating and informing 
families (e.g., Navigators/assisters, hospitals, community health centers, faith-based 
organizations and leaders, community centers, youth sports programs, barbershops, 
nail salons, beauty salons and public libraries). Community-based organizations can 
engage directly with Medicaid and CHIP families about the importance of renewing 
their coverage. These organizations have strong relationships with families and can 
serve as trusted messengers to communicate information in culturally and 
linguistically appropriate ways.  
  Ask schools, early childhood programs, and summer camps to include messaging 
about Medicaid and CHIP renewals. Schools should use existing modes of 
communication (e.g., email, text, calls, backpack flyer/postcards) to get the word out 
to families. Schools should also include messages about redetermination in all back-
to-school paperwork or emails that are required to be completed at the start of the 
school year.  
  Have managed care plans work directly with pediatric providers to track renewal dates 
and support families with assistance to fill out renewal forms.  
 
 
For communication, outreach and education resource materials please see the CMS webpage, 
Medicaid and CHIP Renewals Outreach and Educational Resources.52 
 
VI.  Reporting and Monitoring 
In March 2022, CMS released an Unwinding Eligibility and Enrollment Data Reporting 
Template that states must use to submit the CMS Monthly Unwinding Report during a states 
unwinding period in accordance with the CAA, 2023,53 and the guidance released in SHO #22-
001, Promoting Continuity of Coverage and Distributing Eligibility and Enrollment Workload 
in Medicaid, the Childrens Health Insurance Program (CHIP), and Basic Health Program (BHP) 
 
51 CMS, Medicaid and CHIP Renewals Outreach and Educational Resources, available at https://www.medicaid.gov/resources-
for-states/coronavirus-disease-2019-covid-19/unwinding-and-returning-regular-operations-after-covid-19/medicaid-and-chip-
renewals-outreach-and-educational-resources/index.html.   
52 CMS, Medicaid and CHIP Renewals Outreach and Educational Resources," available at https://www.medicaid.gov/resources-
for-states/coronavirus-disease-2019-covid-19/unwinding-and-returning-regular-operations-after-covid-19/medicaid-and-chip-
renewals-outreach-and-educational-resources/index.html.  
53 CMS, Unwinding Eligibility and Enrollment Data Reporting Template,, available 
https://www.medicaid.gov/sites/default/files/2022-03/unwinding-data-rprt.xlsx.  
 
 
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Upon Conclusion of the COVID-19 Public Health Emergency.54 The required metrics outlined 
in the Unwinding Eligibility and Enrollment Data Reporting Template are designed to 
demonstrate states' progress towards restoring timely application processing and initiating and 
completing renewals of eligibility for all Medicaid and CHIP beneficiaries. In addition to these 
unwinding-specific reports, states must also continue to meet existing reporting requirements, 
including submitting timely data through the Performance Indicator dataset on the 8th of each 
calendar month, and data submissions through the T-MSIS dataset before the end of the 
subsequent calendar month.55 States aggregate reporting for adults and children through the 
Performance Indicator dataset, allowing for more comprehensive Medicaid and CHIP program 
monitoring. States report T-MSIS data at the individual-level, providing more granular data on 
the impact of unwinding on specific eligibility groups.  
 
CMS is closely monitoring states data submissions and encourages states to supplement 
required federal reporting with additional state-specific data. Specifically, CMS encourages 
states to track, analyze, and report publicly the following state-specific metrics during the 
unwinding period:  
  Monthly Medicaid/CHIP terminations among children in household units with parents 
who were disenrolled from Medicaid/CHIP (to identify opportunities for targeted 
outreach).  
  Monthly transition outcomes56 between coverage programs, including: 
  The number of individuals whose accounts are transferred from Medicaid to 
o
separate CHIP; and, of these, the number individuals who subsequently enroll in 
separate CHIP. 
  The number of individuals whose accounts are transferred from CHIP to 
o
Medicaid; and, of these, the number of individuals who subsequently enroll in 
Medicaid. 
 
As a best practice, state-specific data monitoring strategies should also include a breakdown of 
unwinding data by Medicaid eligibility group, the basis for eligibility (e.g., MAGI vs. non-
MAGI), and demographic characteristics (e.g., age, race, ethnicity, language). This supplemental 
data analysis will enable states to track renewal outcomes more closely for Medicaid- and CHIP-
enrolled children and deploy targeted strategies to address those outcomes.  
 
CMS continues to closely monitor changes in Medicaid and CHIP enrollment and is working 
directly with states to identify instances where the data indicate individuals may have lost 
coverage in violation of the Medicaid or CHIP renewal requirements.  
 
 
54 CMS, SHO #22-001, Promoting Continuity of Coverage and Distributing Eligibility and Enrollment Workload in Medicaid, 
the Childrens Health Insurance Program (CHIP), and Basic Health Program (BHP) Upon Conclusion of the COVID-19 Public 
Health Emergency, March 3, 2022, available at https://www.medicaid.gov/federal-policy-guidance/downloads/sho22001.pdf.  
55 CMS, CIB, Key Dates Related to the Medicaid Continuous Enrollment Condition Provisions in the Consolidated 
Appropriations Act, 2023, January 5, 2023, available at: https://www.medicaid.gov/federal-policy-
guidance/downloads/cib010523.pdf. 
56 Section 5131 of the CAA, 2023 requires states to report to CMS monthly data on the number of individuals whose accounts are 
received by the Marketplace (or Basic Health Program) and related outcomes (e.g., qualified health plan eligibility, selection), 
and on the number of individuals enrolled in a separate CHIP.  5131 of the CAA, 2023, (P.L 117-328) available at 
https://www.congress.gov/117/bills/hr2617/BILLS-117hr2617enr.pdf.  
 
 
  Page 19  CMCS Informational Bulletin 
As described in SHO #22-001, CMS continues to monitor states compliance with reporting 
required data and meeting timelines related to initiating and completing required eligibility and 
enrollment actions during the states unwinding period.57 Where reported data or other 
information indicates that states are not meeting unwinding timelines as laid out in the SHO #22-
001 and subsequent guidance, or that states have other persistent compliance issues resulting in 
erroneous disenrollment of eligible beneficiaries, states may be required to provide additional 
data and/or report information more frequently. As described in the CMS SHO #23-002 and 
CMS Interim final rule on the enforcement of state compliance with requirements under section 
1902(tt) of the Act, states that do not resolve their pending actions within the timelines specified 
may be required to submit a corrective action plan to CMS outlining strategies and a timeline to 
come into compliance with federal requirements.58,59 
 
VII.  Closing 
As states restore routine eligibility and enrollment operations during the unwinding period, CMS 
shares states goals of ensuring that eligible children remain enrolled in Medicaid or CHIP and 
that children who are no longer eligible transition seamlessly to other coverage options, 
including Marketplace coverage. CMS is committed to providing states with updated guidance 
and resources, as appropriate, as well as ongoing technical assistance, to better enable states to 
ensure continuity of coverage for Medicaid and CHIP eligible children. For additional 
information and resources, states are encouraged to review guidance and other information 
available at Medicaid.gov/Unwinding. States may also submit questions and request technical 
assistance by contacting their state lead or emailing CMSUnwindingSupport@cms.hhs.gov. 
 
57 CMS, SHO #22-001, Promoting Continuity of Coverage and Distributing Eligibility and Enrollment Workload in Medicaid, 
the Childrens Health Insurance Program (CHIP), and Basic Health Program (BHP) Upon Conclusion of the COVID-19 Public 
Health Emergency, March 3, 2022, available at https://www.medicaid.gov/federal-policy-guidance/downloads/sho22001.pdf.  
58 CMS, SHO #23-002, Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary 
FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, January 27, 
2023, available at: https://www.medicaid.gov/federal-policy-guidance/downloads/sho23002.pdf.  
59 CMS, Medicaid; CMS Enforcement of State Compliance With Reporting and Federal Medicaid Renewal Requirements Under 
Section 1902(tt) of the Social Security Act. December 6, 2023, available at: 
https://www.federalregister.gov/documents/2023/12/06/2023-26640/medicaid-cms-enforcement-of-state-compliance-with-
reporting-and-federal-medicaid-renewal