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:  January 5, 2023 
 
FROM:  Daniel Tsai, Deputy Administrator and Director 
    Center for Medicaid and CHIP Services 
 
SUBJECT:  Key Dates Related to the Medicaid Continuous Enrollment Condition 
Provisions in the Consolidated Appropriations Act, 2023   
 
On Thursday, December 29, 2022, the Consolidated Appropriations Act, 2023 (CAA, 2023) was 
enacted.  This law includes various Medicaid and Childrens Health Insurance Program (CHIP) 
provisions, including significant changes to the continuous enrollment condition at section 
6008(b)(3) of the Families First Coronavirus Response Act (FFCRA) that take effect April 1, 
2023.1  Under this section of the FFCRA, states claiming a temporary 6.2 percentage point 
increase in the Federal Medical Assistance Percentage (FMAP) have been unable to terminate 
enrollment for most individuals enrolled in Medicaid as of March 18, 2020, as a condition of 
receiving the temporary FMAP increase.  When this continuous enrollment condition ends, states 
must, over time, return to normal eligibility and enrollment operations.  As described in prior 
Centers for Medicare & Medicaid Services (CMS) guidance, states will have up to 12 months to 
initiate, and 14 months to complete, a renewal for all individuals enrolled in Medicaid, CHIP, 
and the Basic Health Program (BHP) following the end of the continuous enrollment condition
this process has commonly been referred to as unwinding.2  The newly enacted CAA, 2023 
does not address the end date of the COVID-19 Public Health Emergency (PHE), and as of 
January 2023, the PHE is still in effect; it does, however, address the end of the continuous 
enrollment condition, the temporary FMAP increase, and the unwinding process. 
 
Under the CAA, 2023, expiration of the continuous enrollment condition and receipt of the 
temporary FMAP increase will no longer be linked to the end of the PHE.  The continuous 
enrollment condition will end on March 31, 2023, and the FFCRAs temporary FMAP increase 
will be gradually reduced and phased down beginning April 1, 2023, and will end on December 
31, 2023.  Beginning April 1, 2023, states will be able to terminate Medicaid enrollment for 
individuals no longer eligible.  The conditions for receiving the temporary FMAP increase listed 
at subsections 6008(b)(1), (2), and (4) of the FFCRA will continue to apply to states claiming the 
temporary FMAP increase while the FMAP increase remains available, through December 31, 
2023 (although the CAA, 2023 also amends subsection 6008(b)(2), effective April 1, 2023; CMS 
 
1 Sec. 2, Division FF, Title V, Subtitle D, Sec. 5131, Transitioning from Medicaid FMAP increase requirements of 
the Consolidated Appropriations Act, 2023, available at:  https://www.congress.gov/117/bills/hr2617/BILLS-
117hr2617enr.pdf.  
2 While the requirements of section 6008 of the FFCRA do not apply to separate CHIPs or the Basic Health Program 
(BHP), CMS recognizes some states elected to apply certain provisions of section 6008 to their separate CHIP 
program or BHP. In those circumstances, subject to exceptions noted and other federal requirements, guidance 
related to unwinding from the Medicaid continuous enrollment condition also applies to CHIP and BHP.  Page 2  Key Dates Related to the Medicaid Continuous Enrollment Condition Provisions 
 
will provide additional guidance on this change in the future).  Additionally, the CAA, 2023 
creates a new subsection 6008(f) of the FFCRA that establishes new, additional conditions for 
receiving the FMAP increase, beginning April 1, 2023.  
 
Separately, the CAA, 2023, also establishes a new subsection (tt) of section 1902 of the Social 
Security Act, to require all states to adhere to certain reporting requirements beginning April 1, 
2023, and states that fail to do so may be subject to a reduction in FMAP.  Additional guidance 
on these requirements is forthcoming. 
  
This Center for Medicaid and CHIP Services (CMCS) Informational Bulletin (CIB) is the first in 
a series of guidance for states on the changes to FFCRA section 6008 and other amendments 
related to the unwinding period in the CAA, 2023.  This initial bulletin updates and revises key 
due dates for certain state unwinding deliverables and activities, in light of the enactment of the 
CAA, 2023 (see Appendix A).  CMS will provide additional information related to 
implementation in the coming weeks, and is available to provide states with technical assistance 
as they begin to implement these changes and prepare for the end of the continuous enrollment 
condition.   
 
Key Dates and Activities for States 
 
Expiration of the Continuous Enrollment Condition and Unwinding Timeline 
Sec. 2, Division FF, Title V, Subtitle D, Sec. 5131 of the CAA, 2023 (hereinafter referred to as 
section 5131) amends section 6008(b)(3) of the FFCRA such that the continuous enrollment 
condition will end on March 31, 2023.  With its expiration, beginning April 1, 2023, states 
claiming the temporary FMAP increase under the FFCRA will be able to terminate enrollment 
for ineligible individuals enrolled in Medicaid, following a redetermination.  Consistent with the 
guidance in CMS March 3, 2022 State Health Official Letter #22-001 RE: 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,3 the new March 31, 2023 statutory end date of the 
continuous enrollment condition means that states could begin their 12-month unwinding period 
and initiate the first Medicaid renewals that may result in disenrollment as early as February 1, 
2023.  As explained in SHO Letter #22-001, states should begin renewals in the month before, 
of, or after the month in which the continuous enrollment condition ends (i.e., in light of the 
CAAs amendment, February, March, or April 2023), must initiate renewals for all individuals 
enrolled as of the last day of the continuous enrollment condition within 12 months (i.e., in light 
of the CAAs amendment, March 31, 2024), and must complete renewals for individuals enrolled 
as of the last day of the continuous enrollment condition within 14 months (i.e., in light of the 
CAAs amendment, May 31, 2024) (see Appendix B).  The CAA, 2023 does not modify the 
duration of the unwinding period. 
 
Redeterminations must be conducted in accordance with all applicable federal requirements, 
which could include using strategies approved under section 1902(e)(14)(A) of the Social 
Security Act or other alternative processes and procedures approved by CMS.  Section 
5131(a)(4) of the CAA establishes section 6008(f) of the FFCRA, which makes following these 
 
3 https://www.medicaid.gov/federal-policy-guidance/downloads/sho22001.pdf  
 
  Page 3  Key Dates Related to the Medicaid Continuous Enrollment Condition Provisions 
 
requirements a condition of receiving the FMAP increase from April 1, 2023 through December 
31, 2023.  It also requires states claiming the FMAP increase during this time period to meet 
new, additional conditions related to conducting eligibility redeterminations, including using 
certain specified sources to attempt to ensure that the state has up-to-date contact information for 
each individual for whom it conducts a redetermination, and undertaking a good faith effort to 
contact using more than one modality any individual who is determined ineligible on the basis of 
returned mail prior to disenrolling that person.  These and other provisions will be addressed in 
forthcoming guidance.  
 
Submission of Required Documentation 
Prior to beginning their unwinding period, we expect states to submit certain documents to CMS. 
As indicated in SHO Letter #22-001, these reporting activities are designed to ensure that 
renewals of eligibility occur in an orderly process that minimizes beneficiary burden and 
promotes continuity of coverage, including for individuals eligible for other insurance 
affordability programs, and maximizes state effectiveness.  The reporting metrics are designed to 
demonstrate states progress towards restoring timely application processing and initiating and 
completing renewals of eligibility for all Medicaid and CHIP enrollees, consistent with CMS 
guidance. 
 
Below are revised and updated due dates for certain state deliverables: 
  Renewal Redistribution Plan is due no later than February 1, 2023, for states that intend 
to begin renewals in February, or February 15, 2023, for all other states. 
  System Readiness Artifacts (Configuration plan, testing plan, and test results) are due 
no later than February 1, 2023, for states that intend to begin renewals in February, or 
February 15, 2023 for all other states. 
  Baseline Unwinding Data is due the 8th day of the month in which a state begins 
renewals. 
 
      Submission  Submit by: 
      Renewal Redistribution Plan    February 1, 2023, for states initiating renewals in 
February 
  February 15, 2023, for all other states 
      Systems Readiness Artifacts    February 1, 2023, for states initiating renewals in 
(Testing and Configuration Plans)   February 
  February 15, 2023, for all other states 
      Baseline Unwinding Data        Varies depending on when state begins renewals 
    (February 8, 2023, March 8, 2023, or April 8, 2023) 
Note: Where a submission due date falls on a weekend or public holiday, states may submit the 
required document(s) (e.g., unwinding data) on the following business day.  
 
In addition to submission of baseline unwinding data on February 8, March 8, or April 8, we 
want to remind states of requirements to report data timely throughout the unwinding period.  As 
outlined in the Unwinding Data Reporting Specifications4 and COVID-19 PHE Unwinding 
 
4 https://www.medicaid.gov/resources-for-states/downloads/unwinding-data-specifications.pdf.  
 
  Page 4  Key Dates Related to the Medicaid Continuous Enrollment Condition Provisions 
 
FAQs5 on the 8th of each calendar month during the unwinding period, states will report on 
specific metrics to demonstrate progress towards initiating and completing renewals of eligibility 
for all Medicaid and CHIP enrollees.  Additionally, CMS expects that states will continue to 
submit timely data submissions through the Medicaid and CHIP Eligibility and Enrollment 
Performance Indicator dataset on the 8th of each calendar month, and data submissions through 
the Transformed Medicaid Statistical Information System (T-MSIS) dataset before the end of the 
subsequent calendar month.  The CAA, 2023 established additional reporting requirements 
related to states eligibility redeterminations and renewals during the period from April 1, 2023 
to June 30, 2024.  These requirements are established under section 1902(tt) of the Social 
Security Act.  CMS expects to issue guidance soon about those new reporting requirements and 
how they intersect with the requirements described in CMSs previous unwinding guidance, 
including the Unwinding Data Report template and specifications. 
 
Upcoming Activities: 
In January 2023, CMCS will contact State Medicaid Directors to schedule individual meetings 
with each state to discuss final unwinding plans and state questions.  CMCS will also contact 
state Systems Leads to schedule individual meetings to discuss systems readiness, testing, and 
any planned mitigations.  CMS also expects to provide additional guidance on other aspects of 
section 5131 of the CAA, 2023, including the new reporting requirements.  For additional 
information in the interim, states are encouraged to review guidance and other information 
posted to Medicaid.gov/Unwinding.  States may also submit technical assistance questions 
directly to CMSUnwindingSupport@cms.hhs.gov.  
 
 
 
 
5 https://www.medicaid.gov/federal-policy-guidance/downloads/covid-19-unwinding-faqs-oct-2022.pdf.  
 
  Page 5  Key Dates Related to the Medicaid Continuous Enrollment Condition Provisions 
 
Appendix A: Timeline of Key State Activities 
 
Consolidated Appropriations Act (CAA), 2023. Enacted December 29, 2022 
Continuous Enrollment Requirement Expires March 31, 2023 
3/31/23 
Continuous enrollment condition 
expires
2/1/23 4/1/23
First day in which  Terminations may begin
12/29/22 
states may initiate 
Temporary increased FMAPdecreases 
CAA 2023 is 
renewals for April 
to 5 percentage points for Q2 2023 for 
enacted
terminations
qualifying states
Dec 2022 Jan 2023 Feb 2023 Mar 2023 Apr 2023
Week of 1/17/23 2/1/23 2/15/23
Begin CMS/State  If initiating renewals  If initiating renewals in 
meetings on  in February: last day  March or April, last day 
unwinding  to submit: to submit: 
planning &  Renewal  Renewal Redistribution 
systems  Redistribution Plan  Plan 
readiness System  System Configuration 
Configuration Plan Plan
System Test Plan and  System Test Plan and 
results results
 
Key CAA 2023 milestones  
State actions related to renewals and key timelines for submission of 
deliverables to CMS 
Data reporting: Baseline unwinding data submission dates will vary by state and will be due on either 2/8/2023, 3/8/2023, or 4/8/2023. 
th
Thereafter, monthly unwinding data submissions will be due on the 8  of the month. State data submissions through the Medicaid and 
th
CHIP Performance Indicator dataset are also due on the 8  each month, and state data submissions through the Transformed Medicaid 
Statistical Information System (T-MSIS) dataset are due before the end of the subsequent calendar month.   
 
 
  Page 6  Key Dates Related to the Medicaid Continuous Enrollment Condition Provisions 
 
Appendix B1  Example 1: Unwinding Timeline for States with a 60-day Renewal Process 
March 31: 
States only  States processing  States only 
End of Continuous 
initiating renewals  renewals, including  completing 
Enrollment Condition that may result in  effectuating   renewals
terminations1 terminations
Option A: State begins 12-month unwinding period in February 2023 (two months prior to the end of the continuous enrollment requirement)
1 2 3 4 5 6 7 8 9 10 11 12 13 14
Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar
Month 1: Feb.2023 Month 12: Jan.  Month 14: Mar. 
Begin initiating  2024 2024
unwinding-related  Last month to  Last month to 
renewals initiate unwinding- complete all 
related renewals unwinding-
related 
renewals
Option B:  State begins 12-month unwinding period in March 2023 (the month in which the continuous enrollment requirement ends)
1 2 3 4 5 6 7 8 9 10 11 12 13 14
Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr
Month 1: Mar. Month 12: Feb.  Month 14: Apr. 
2023 2024 2024
Begin initiating  Last month to  Last month to 
unwinding- initiate unwinding- complete all 
related  related renewals unwinding-related 
renewals renewals
Option C: State begins 12-month unwinding period in April 2023 (the month after the month in which the continuous enrollment requirementends)
1 2 3 4 5 6 7 8 9 10 11 12 13 14
Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr May
Month 1: Apr.  Month 12: Mar.  Month 14: May 
2023 2024 2024
Begin initiating  Last month to  Last month to 
unwinding- initiate unwinding- complete all 
related  related renewals unwinding-related 
renewals renewals
  
1.  For Options B and C above, states that begin their unwinding period in March or April 2023 are not prohibited from completing renewals after 
March 31, 2023, provided that the renewals are conducted in accordance with federal requirements at 42 C.F.R.  435.916 and 457.343, including 
requirements to provide beneficiaries sufficient time to return a renewal form and needed documentation.  
 
 
  Page 7  Key Dates Related to the Medicaid Continuous Enrollment Condition Provisions 
 
Appendix B2  Example  Unwinding Timeline for State with a 90-Day Renewal Process 
End of PHE
March 31: 
States only initiating  States processing  States only 
End of Continuous 
renewals that may  renewals, including  completing 
Enrollment Condition
result in  effectuating   renewals
terminations1 terminations
1 2 3 4 5 6 7 8 9 10 11 12 13 14
Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar
Month 1: Feb. 2023 Month 12: Jan  Month 14: Mar. 2024
Begin initiating  2024 Last month to 
unwinding-related  Last month to  complete all 
renewals initiate unwinding- unwinding-related 
related renewals renewals
1 2 3 4 5 6 7 8 9 10 11 12 13 14
Mar Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb Mar Apr
Month 1: Mar. 2023 Month 12: Feb.  Month 14: Apr. 2024
Begin initiating  2024 Last month to 
unwinding-related  Last month to  complete all 
renewals initiate unwinding- unwinding-related 
related renewals renewals
1 2 3 4 5 6 7 8 9 10 11 12 13 14
Apr May Jun Jul Aug Sep Oct Nov Dec Jan Feb MJualr Apr May
Month 1: Month 12:  Month 14: 
Apr. 2023 Mar. 2024 May 2024
Begin initiating  Last month to  Last month to 
unwinding- initiate unwinding- complete all 
related  related renewals unwinding-related 
renewals renewals  
1.  States are not prohibited from completing renewals after March 31, 2023, provided that the renewals are conducted in accordance with federal 
requirements at 42 C.F.R.  435.916 and 457.343, including requirements to provide beneficiaries sufficient time to return a renewal form and needed 
documentation.