DEPARTMENTOFHEALTH&HUMANSERVICES
Centers forMedicare &MedicaidServices
7500SecurityBoulevard,MailStopS2-26-12
Baltimore,Maryland 21244-1850
CMCSInformational Bulletin
DATE: December 18, 2023
FROM: DanielTsai,DeputyAdministratorandDirector,CenterforMedicaid & CHIPServices
SUBJECT: Ensuring Eligible ChildrenMaintainMedicaidandChildrens Health
Insurance ProgramCoverage
The purpose of this CMCSInformational Bulletin (CIB) is to remind states about federal
eligibility requirementsandavailableflexibilitiestopromotecontinuity 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
childrenwereenrolledinMedicaidandCHIP.1Together,theprograms provide health coverage
tooverhalf of allchildrenin the United States (U.S.), includingmillions of children and youth
with special health care needs. Medicaid and CHIPcover essential services and supports for
children, includingvisits to the pediatrician, regular screenings, mental health care, childhood
immunizations, and emergency care. In addition to better short-term health and well-being,
MedicaidandCHIPcoveragehasalsobeenshowntoprovidelong-termhealth,educational, and
economicgainsforchildren.Forexample,inarecentanalysis,theCongressional Budget Office
(CBO) foundthatanadditionalyearofMedicaidcoverageinchildhoodwould lead to improved
labor outcomes in adulthood, includinghigher earnings.2
It is crucial that states do all they can to protect childrens health coverage. The Consolidated
AppropriationsAct,2023(CAA,2023)endedtheMedicaidcontinuous enrollment condition on
March 31, 2023, requiringstates to, over time, complete full Medicaid renewals and disenroll
andreferindividualstoothersourcesofcoverageif theyaredeterminedtono longer be eligible.
Thisprocessisoftenreferredto as unwinding. CMSis particularly concerned about children
that are disenrolled for procedural or administrative reasons (e.g., missingrenewal form
information). Many of these children are likely still eligible for coverage otherwise.
Sincethebeginningof theunwindingperiod,enrollmentinMedicaid and CHIPamongchildren
hasdeclinedby2.2million.Whilesomechildrenmayhavetransitionedtootherforms of health
coverage, children have higher eligibility levels than adults, and it is likely that many children
thathavebeendisenrolledforproceduralreasonsorotheradministrativebarriersarestill income
eligible forMedicaidandCHIPcoverage.Thismayhavedevastatingeffectsonchildrenshealth
and well-being.
1CMS,March2023MedicaidandCHIPEnrollmentDataHighlights,July2023,availableat
https://www.medicaid.gov/medicaid/program-information/medicaid-and-chip-enrollment-data/report-highlights/index.html.
2CongressionalBudgetOffice,ExploringtheEffectsofMedicaidDuringChildhoodontheEconomyandtheBudget:Working
Paper2023-27,November1,2023,availableathttps://www.cbo.gov/publication/59231 Page 2  CMCSInformational Bulletin
States havetheopportunitytoadoptstrategiesthatreduceredtapeto help keep eligible children
covered. The Centers for Medicare & Medicaid Services (CMS) is callingupon all states to
redouble their efforts to implement policies and operational processes, conduct enhanced
outreach,adoptallavailablewaivers and flexibilities, and monitor data to ensure children who
remain eligible for Medicaid and CHIPdo not lose coverage. Page 3  CMCSInformational Bulletin
Executive Summary
ThisCIB outlinesfederalrenewalrequirements and offers additional, actionable strategies that
statescanadopttopromotecontinuouscoverageforchildrenandyouthwhoarelikelyeligiblein
Medicaid and CHIP. Key takeaways, described in further detail in the pages following, are:
 Federal Renewal Requirements.
o States are required to conduct redeterminations of eligibility for all individuals
enrolledinMedicaid and CHIPin compliance with federal requirements. States
mustfirstattemptto renew eligibility for all Medicaid Modified Adjusted Gross
Income(MAGI)andnon-MAGIandCHIPbeneficiaries based on available data
without requiringadditional information from the individual (referred to as ex
parterenewal).Statesmustsendarenewalform only if available information is
insufficienttorenewtheindividualseligibilityon an ex parte basis. States must
conductrenewals at the individual level, includingfor children in families with
mixedimmigrationandcitizenshipstatus.Inmanyfamilies,childrenmay still be
eligible even if parents no longer meet Medicaid eligibility criteria and are
referred to Marketplace coverage.
o States may not deny or delay a redetermination to an otherwise eligible
individual, includingindividuals who were initially eligible for Medicaid or
CHIPas deemed newborns, as longas the family is attemptingto obtain a
social security number (SSN) for the infant.
o States may not delay a renewal for Medicaid and CHIPpendinginformation
needed to complete a redetermination or due to other requirements for another
human services program (e.g., the Supplemental Nutrition Assistance Program
(SNAP)).
o Effective January 1, 2024, all states will be required to provide 12-month
continuous eligibility for children in Medicaid and CHIP.
 ChildrenandYouthwithSpecialHealthCare 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
childrenandminimizecoverageloss.Thismayinclude partneringwith other entities
thatservetheseyouthandtheirfamilies,deployingassisters,andleveragingMedicaid
managed care plans to support renewals.
 Supporting Seamless Transitions Across Programs. States must support seamless
transitionsacrossMedicaidandCHIPat renewal. Specifically, when a state reviews
availabledatasourcesandfindsthataMedicaid-enrolled child appears to be eligible
for a separate CHIP, or a separate CHIP-enrolled child appears to be eligible for
Medicaid,thestatemustsendarenewalformandgivethe household an opportunity
to refute the information. CMSurges states to rely on data obtained by the state
Medicaidorseparate CHIPagency duringan 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 CHIPprograms, Page 4  CMCSInformational Bulletin
ensurecontinuouscoverageforchildren,and avoid procedural terminations. CMSis
concerned that in states that choose not to adopt this approach, children otherwise
eligible for coverage are not successfully renewingtheir eligibility for Medicaid or
CHIP.
 Additional Strategies States Can Adopt to Promote Continuity of Coverage. States
shouldadoptavailablefederalauthoritiesandflexibilitiesto maximize Medicaid and
CHIPcoverageretentionfor eligible individuals. Specifically, these strategies allow
states to:
o Increase ex parte renewal rates by adoptingExpress Lane Eligibility for
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 Duringthe COVID-19 Unwinding
Period).3 States with low ex-parte rates can also adopt additional strategies to
modifyhowtheyuseavailabledatatosignificantly increase the success rate of
ex-parte renewals, thereby keepingmore eligible kids enrolled.
o Strengthenoutreachandrenewal assistance by partnering withMedicaid
andCHIP managedcare plans to share data on upcomingmember renewals,
conduct targeted outreach and provide renewal assistance to families.
o Maintaincontinuity of coverage by providing multi-year continuous
eligibility for children through section 1115 demonstration authority.
o Maximize CHIP retentionby eliminating or suspending premiums or
enrollment fees andremoving premiumlock-out periods. States can also
eliminate waitingperiods and implement alternative strategies to monitor
substitution of coverage.
o Increase retentionby temporarily delaying or pausing procedural
disenrollments forbeneficiariesforoneormoremonthswhilethestateconducts
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
CMSrecentlygrantedwaiverauthoritytotwostatesto extend renewals for children for
up to 12 months, to prevent procedural disenrollments of eligible children. Additional
states interested in adoptingthis strategy are encouraged to contact CMS. Further, to
support states efforts to establish and update income and eligibility determination
systems that protect beneficiaries by maximizingstates ability to ensure that eligible
individuals retain coverage, CMSwill extend all unwinding-related waivers provided
3CMS,AvailableStateStrategiestoMinimizeTerminationsforProceduralReasonsDuringtheCOVID-19UnwindingPeriod,
June2023,availableathttps://www.medicaid.gov/sites/default/files/2023-06/state-strategies-to-prevent-procedural-
terminations.pdf.
4https://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  CMCSInformational Bulletin
under1902(e)(14)(A)of theActthroughDecember31,2024, unless later date has been
approved by CMS. States may also continue to request new waiver authorities for
implementation through December 31, 2024. CMScontinues to assess the impact of
thesewaiverstodeterminewhichmayimplemented under other authorities. Additional
guidance on the continued availability of these strategies is forthcoming.
 Outreach to Families and Strengthening Community Partnerships. State Medicaid and
CHIPagenciesareencouragedtocollaboratewithotherfamily-facingstate agencies and
community partners, such as schools and community-based organizations, to ensure
familieshaveup-to-dateinformationabouttheredeterminationprocess,includingwhatis
required to keep eligible children enrolled in coverage. This may include workingwith
schoolstoincludemessagingaboutMedicaidandCHIPrenewalsandengagingmanaged
care plans.
 ReportingandMonitoring.Statesarerequiredto submit monthly reports to demonstrate
state progress towards restoringtimely application processingand initiatingand
completingrenewalsof eligibilityforallMedicaidandCHIPbeneficiaries.Inaddition to
these unwinding-specific reports, states must also continue to meet existingmonthly
reportingrequirements,includingsubmittingtimelydatathroughtheMedicaidand CHIP
Eligibility andEnrollmentPerformanceIndicator(Performance Indicator) dataset and
datasubmissionsthrough the Transformed Medicaid Statistical Information System (T-
MSIS) dataset.Statesarealsoencouragedtosupplementtheirfederalreportingwith their
own state-specific data analysis.
CMSis supportingstates by makingflexibilities available to reduce coverage loss for eligible
childrenandofferingpolicyandoperationaltechnicalassistance.CMSis also monitoringstates
activities to ensure that children have access to the coverage and care they need duringthe
Medicaid unwindingperiod and beyond. CMS will continue to use the enforcement and
oversight levers at its disposal to ensure state compliance with federal requirements (and
implementapproved mitigation strategies when out of compliance) intended to protect eligible
children from losingcoverage. Page 6  CMCSInformational Bulletin
CMCSInformational Bulletin
EnsuringEligible Children Maintain Medicaid and Childrens Health Insurance Program
Coverage Duringthe UnwindingPeriod and Beyond
Table of Contents
I. Federal RenewalRequirements......................................................................................7
a. Children in Families withMixed Immigrationand CitizenshipStatus..............................9
b. Deemed Newborns........................................................................................................9
II. ChildrenandYouthwithSpecial HealthCare Needs..................................................10
III. Supporting Seamless TransitionsAcross Programs.....................................................11
IV. Additional Strategies toPromote Continuity of Coverage...........................................12
a. Leveraging Section1902(e)(14)(A) Waivers.................................................................12
b. Partnering with Managed CarePlans..........................................................................13
c. Providing Continuous Eligibility for Children..............................................................14
d. Implementing ExpressLane Eligibility.........................................................................14
e. ModifyingCHIP Premium Policies..............................................................................14
f. ModifyingPoliciesforSubstitution of Coverage in Separate CHIP...............................15
g. Delaying Procedural Disenrollments forChildren to Enhance Outreach.......................16
V. Messaging toFamilies andStrengthening Community Partnerships..........................16
VI. ReportingandMonitoring............................................................................................17
VII.Closing..........................................................................................................................19 Page 7  CMCSInformational Bulletin
I. Federal Renewal Requirements
States are required to conduct redeterminations of eligibility for all individuals enrolled in
Medicaid and CHIPin compliance with federal requirements at 42 C.F.R.  435.916 and
457.343andasoutlinedintheCIB,MedicaidandChildrensHealthInsuranceProgram (CHIP)
RenewalRequirements.5Whilethis informational bulletin provides a general overview of the
renewalrequirements,statesshouldrefertothefederalrequirementsat42C.F.R.435.916and
457.343 and the CIB, Medicaid and Childrens Health Insurance Program (CHIP) Renewal
Requirements, for a complete understandingof the renewal requirements. CMSis also
available to provide technical assistance to states.
At renewal,statesarerequiredtofirst attempt to renew eligibility for all MAGI and non-MAGI
Medicaid and CHIPbeneficiaries based on reliable information available to the state agency
without requiringinformation from the individual.6 Such renewals are referred to as ex parte
renewals.7If theagencyisable to renew eligibility based on available reliable information, the
agencymustprovidenoticeof thedeterminationandbasisforeligibility,8andtheindividualmay
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
mustsendarenewalformandrequestonlytheinformationnecessarytoredetermineeligibility.10
Renewal forms must be prepopulated for MAGI-based Medicaid and CHIPbeneficiaries, and
statesareencouragedtouseprepopulatedrenewalformsattheiroptionfornon-MAGI Medicaid
beneficiaries.11Theagencyisencouragedtoprovideaprepopulatedrenewalformfornon-MAGI
beneficiaries.12 States must provide MAGI beneficiaries a minimum of 30 days to return the
prepopulatedrenewalformand 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
completetheformandcorrectanyinaccurateprepopulatedinformation,howthe 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
andpersons with disabilities.16 The agency must continue to furnish Medicaid to beneficiaries
whohavereturnedtheirrenewalformandallrequesteddocumentation unless and until they are
determined to be ineligible.17 States may not delay a renewal for Medicaid and CHIPpending
542C.F.R.435.916;CMS,CIB,MedicaidandChildrensHealthInsuranceProgram(CHIP)RenewalRequirements,
December4,2020,availableathttps://www.medicaid.gov/federal-policy-guidance/downloads/cib120420.pdf.
642C.F.R.435.916(a)(2)and(b)and457.343.
7Anexparterenewalissometimesreferredtoasautorenewal,passiverenewal,oradministrativerenewal.
8Noticemustbeprovidedconsistentwith42C.F.R.435.917,Part431,subpartE,and457.340(e),asapplicable.
942C.F.R.435.916(a)(2)(i)and(ii)and435.916(b),435.917,and457.343.
1042C.F.R.435.916(a)(3),435.916(b),435.916(e),and457.343.
1142C.F.R.435.916(a)(3)(i)(A)and457.343.
1242C.F.R.435.916(b).
1342C.F.R.435.916(a)(3)(i)(B)and457.343.
1442C.F.R.435.952.
1542C.F.R.435.905(b)and457.340;CMS,CIB,MedicaidandChildrensHealthInsuranceProgram(CHIP)Renewal
Requirements,December4,2020,availableathttps://www.medicaid.gov/federal-policy-guidance/downloads/cib120420.pdf.
1642C.F.R.435.916(g).
1742C.F.R.435.930(b). Page 8  CMCSInformational Bulletin
information needed to complete a redetermination or other requirements for another human
services program (e.g., the Supplemental Nutrition Assistance Program (SNAP)).
States mustdetermine and redetermine Medicaid and CHIPeligibility on an individual basis.18
Whenmultiplemembersof ahouseholdareenrolledinMedicaidorCHIP,thestatemay process
renewalsforan entire household or multiple members of a household at the same time if their
eligibility periodsarealigned.However,thestate must conduct the renewal for each individual
consistentwith42C.F.R.435.916and457.343,includingrenewingeligibility on an ex parte
basis for each individual in the household, if able to do so, and only requestinginformation
necessarytoredetermineeligibilityforthoseindividualswhothestatecannot 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,
evenwhenaparentor guardian is no longer eligible for Medicaid, a child may remain eligible,
duetohigherincomelimits.Themedianupperincomelimit for children in Medicaid and CHIP
is 255percentofthefederalpovertylevel(FPL)comparedto133percent of the FPL for adults.
NearlyallstateshaveestablishedchildrenseligibilitylevelsforMedicaid-expansionor separate
CHIPprograms at or above 200 percent of the FPL.
Ininstanceswherestatesare unable to renew eligibility for a parent or guardian on an ex parte
basis,statesmuststill reneweligibilityonanexpartebasisforchildrenorother members of the
householdforwhomthestatehassufficientinformationtodeterminecontinuedeligibility.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
householda renewal form. For additional information and examples, see CMSState Medicaid
Director Letter (SMDL), EnsuringCompliance with Requirements to Conduct Medicaid and
CHIPRenewal Requirements at the Individual Level, Attachment B.19
Importantremindersforconductingredeterminations of eligibility at the individual level for
Medicaid- and CHIP-enrolled children:
 States mustdetermineandredetermineMedicaidandCHIPeligibilityonanindividual
basis,includingforchildreninhouseholdswithatleastoneadultenrolledinMedicaid
and for children in families with mixed immigration and citizenship status.
 Ininstanceswherestatesareunabletoreneweligibilityforaparentor guardian on an
exparte basis, states must still renew eligibility on an ex parte basis for children for
whom the state has sufficient information to determine continued eligibility.
1842C.F.R.435.911(c),435.926,457.343,and457.350(b)(1).
19CMS,SMDL,EnsuringCompliancewithRequirementstoConductMedicaidandCHIPRenewalRequirementsatthe
IndividualLevel,August30,2023,availableathttps://www.medicaid.gov/media/162301,and5112oftheConsolidated
AppropriationsAct,2023(CAA,2023)(P.L117-328),availableathttps://www.congress.gov/117/bills/hr2617/BILLS-
117hr2617enr.pdf. Page 9  CMCSInformational Bulletin
 States maynotrequirehouseholdmemberswhoseeligibilitymayberenewedonanex
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
Insomecases,childrenareeligibleforMedicaidorCHIPevenif 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 enrollingin or maintainingMedicaid or CHIP.
Individualsmayapply 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
determinedseparatelyforeachmemberof thehouseholdandthatinabilityto verify immigration
statusforoneormorehouseholdmembersdoesnotimpedetheinitialeligibilitydeterminationor
abilityforastate to complete a renewal, includingon an ex parte basis, for another household
member.21
For individuals, includingchildren, enrolled in Medicaid, state Medicaid agencies may not
reverifycitizenshipatrenewal,unlesstheindividualreportsachangeincitizenshiportheagency
hasreceivedinformationindicatingapotentialchangeintheindividual'scitizenship.22Similarly,
anindividualsimmigrationstatusdoesnotneedtobereverifiedif itisnotlikelytochange (e.g.,
LawfulPermanentResident status) unless the individual reports such a change has occurred.23
b. Deemed Newborns
States mustdeeminfantsborntopregnantindividualswhoareeligiblefor and received covered
servicesinMedicaidor CHIPas continuously eligible from birth until the childs first birthday
withoutrequiringanapplication.24Whentheinfantwhowasdeemed Medicaid or CHIPeligible
at birthisdueforrenewalafterthefirstyear, states must first attempt an ex parte renewal prior
torequestingadditionalinformation,if needed, andmaynotrequirethefamilytoreapplyforthe
infant to retain coverage. Individuals who were initially eligible for Medicaid or CHIPas
deemednewbornsareconsideredtohaveprovided satisfactory documentation of citizenship
and identity (by virtue of beingborn in the U.S.) and are not required to further document
citizenship or nationality in any subsequent Medicaid or CHIPredetermination.25 States must
assistfamilieswithapplyingforanSSNif theydonothaveoneorwithverifyingan SSN if they
cannotrecallthenumber.26Anagencymaynotdenyordelay a redetermination to an otherwise
20UnitedStatesDepartmentofHealthandHumanServices,HealthCoverageOptionsforImmigrants,July2022,availableat
https://www.hhs.gov/guidance/sites/default/files/hhs-guidance-documents/Health-Coverage-Options-Immigrants-2022.pdf.
2142C.F.R.435.911.
2242C.F.R.435.956(a)(4).
23CMS,CIB, MedicaidandChildrensHealthInsuranceProgram(CHIP)RenewalRequirements,December4,2020,available
athttps://www.medicaid.gov/federal-policy-guidance/downloads/cib120420.pdf.
24Section1902(e)(4)and2112(e)oftheAct;42C.F.R. 435.117and457.360.InCHIP,statesmustprovidedeemednewborn
coveragetochildrenborntopregnantindividualswhowereeligibleforCHIPcoverageastargetedlow-incomepregnant
women.Statesmayalsoelecttoprovidedeemednewbornscoverageforinfantsborntopregnanttargetedlow-incomechildren.
25Section1903(x)(2)(D)oftheAct.
2642C.F.R.435.910(e),435.956,and457.340(b). Page 10  CMCSInformational Bulletin
eligible individual pendingissuance or verification of the SSN, as longas the family is
attemptingto obtain an SSN for the infant.27
II. ChildrenandYouthwithSpecial HealthCare 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 CHIPdaily for life-sustaining
treatment, includingmedications, durable medical equipment, home care, and medical care.28
States shouldconsiderdeployingstrategiesspecifically focused on mitigatingcoverage loss for
children and youth with special health care needs (CYSHN)29.
IdentifyingCYSHNenablesMedicaidandCHIPagencies to better support retention of eligible
high-risk individuals duringrenewal and on an ongoingbasis. States can identify CYSHN in a
number of ways, includingbased on:
 Eligibility group, includingchildren and youth enrolled in eligibility categories for
individuals with disabilities, or former foster care youth;
 Receiptof specializedorhigh-riskcareforphysicalorbehavioralhealthneeds,including
through state plan benefits (such as targeted case management or health homes),
demonstrationprojectsundersection1115oftheSocialSecurityAct(theAct),homeand
community-based services waivers; and
 Claimsandencounterdatatoidentifychildrenandyouthinanactivecourseof treatment
for a complex illness (e.g., children or youth receivingcancer treatment).
Tominimizelossof coverageandpromotecontinuityofcareforeligiblechildren,state agencies
are strongly encouraged to:
 Partnerwithotherentities,includingTitle V and other state programs providingsupport
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 providinglonger timeframes for
individuals to respond to requests for information to complete the renewal process,
followingupwithmultipleoutreachesthroughalternatemodalitiesfor beneficiaries who
donotrespondtorenewalformsandrequestsforadditionalinformation, 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.
2742C.F.R.435.910(f),435.956,and457.340(b).
28MedicaidandCHIPPaymentandAccessCommission,MedicaidAccessinBrief:ChildrenandYouth
withSpecialHealthCareNeeds,March2023,availableathttps://www.macpac.gov/wp-content/uploads/2023/03/Medicaid-
Access-in-Brief-Children-and-Youth-with-Special-Health-Care-Needs.pdf,
29CMS,MedicaidUnwinding:AnAll-Hands-On-DeckStrategytoSupportOutreachtoChildrenandFamilies,August2023,
availableathttps://www.medicaid.gov/media/161661. Page 11  CMCSInformational Bulletin
III. Supporting Seamless Transitions Across Programs
MedicaidandCHIPagenciesmusthaverenewalprocessesinplacethatensure 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-benefitMedicaid coverage under all
bases, it must determine potential eligibility for other insurance affordability programs (e.g.,
separateCHIPorMarketplacecoverage)andtransferthatindividualselectronicaccounttosuch
program,asappropriate.30Similarly,if astatedeterminesthataseparate CHIPbeneficiary is no
longer eligible, it must screen the individual for eligibility in other insurance affordability
programs, includingMedicaid (on all bases) and Marketplace coverage.31 If the child is
determinedpotentiallyeligibleforanothercoverage program, the state must transfer the childs
account to that program.32
At renewal,whenastatereviewsavailabledatasourcesandfindsthata Medicaid-enrolled child
appears to be eligible for a separate CHIP, or a separate CHIP-enrolled child appears to be
eligible forMedicaid,thestatemustsendarenewalformandgivethehousehold an opportunity
torefutetheinformation.33If thefamily does not return the form, the state should complete an
eligibility determinationbasedonavailableinformationandenrollthechildintheother program
for which such information indicates they are eligible. States must maintain the child in the
currentcoverageprogrampriortoexecutinganyadverseaction(i.e.,terminatingcoverage under
either program).
As described in CMS guidance on SupportingSeamless Coverage Transitions for Children
MovingBetween Medicaid and CHIPin Separate CHIPStates, data obtained by the state
MedicaidorseparateCHIPagencyduringanexpartereviewmaybeusedtomakethe eligibility
determinationinthe other program.34 This helps to facilitate transitions between Medicaid and
CHIPto ensure continuous coverage for children and avoid procedural terminations when the
state finds the child eligible usingavailable and reliable data.
In order to mitigate coverage loss for eligible children transitioningbetween coverage
programs if a family does not respond to a renewal form, CMSrecommends that :
(1) Medicaid agencies use the data obtained by CHIPduringthe ex parte review to
make a determination of eligibility and enroll the child in Medicaid (if eligible)
without requestingadditional information to confirm Medicaid eligibility; and
(2)CHIPagenciesusethe data obtained by the Medicaid agency duringthe ex parte
review to make a determination of eligibility and enroll the child in CHIPwithout
requestingadditional information to confirm CHIPeligibility.
3042C.F.R.435.916(f).
3142C.F.R.457.350(b).
3242C.F.R.435.1200(e)(1)and457.351
3342C.F.R.435.916and457.343.
34CMS,SupportingSeamlessCoverageTransitionsforChildrenMovingBetweenMedicaidandCHIPinSeparateCHIP
States,December12,2022,availableathttps://www.medicaid.gov/resources-for-states/downloads/supporting-medicaid-chip-
transitions.pdf. Page 12  CMCSInformational Bulletin
For children whose household income is above CHIPeligibility 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
retentioninMedicaidandCHIPandhelpensuresmoothtransitionstootherhealthcarecoverage
for children leavingthe 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
operationsfollowingtheendof the Medicaid continuous enrollment condition, CMShas made
available a number of authorities under Section 1902(e)(14)(A) of the Act.36 Section
1902(e)(14)(A)of theAct,addedbySection2002oftheAffordableCareAct,allowsforwaivers
asarenecessarytoensurethatstatesestablishincomeandeligibilitydeterminationsystems that
protect beneficiaries. To support states efforts to establish and update income and eligibility
determination systems that protect beneficiaries by maximizingstates ability to ensure that
eligible individuals retain coverage, CMSwill 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. CMScontinues to assess the impact of these
waiverstodetermine which may implemented under other authorities. Additional guidance on
the continued availability of these strategies is forthcoming.
Severalsection1902(e)(14)(A)strategiescanhelpstatesincreaseexparterates and enhance the
ex parte process for children and youth, in effect minimizingloss of coverage. Since ex parte
renewalsrelyonverifyingeligibilityusingavailableandreliableinformation,therenewalcanbe
completed without requiringthe beneficiary to return a renewal form or provide other
information and/or documentation. As such, the risk of coverage loss for procedural reasons
amongbeneficiaries who meet the substantive eligibility criteria is significantly reduced.
Examples of strategies authorized usingwaiver 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
basedonfinancialfindingsfromSNAP,TANF,orothermeans-tested programs. This
flexibilitycanalsobeappliedtoCHIPinstateswheretheSNAPorothermeans-tested
program eligibility levels are higher than the Medicaid level and below the CHIP
levels.
3542C.F.R457.350.
36CMS,COVID-19PHEUnwindingSection1902(e)(14)(A)WaiverApprovals,October2023,availableat
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  CMCSInformational Bulletin
 Beneficiaries with No Income Renewal Strategy, which allows states to renew
eligibility onanexpartebasisforMAGIand non-MAGI individuals with $0 income
when no data is returned.
 Beneficiaries with Low Income Renewal Strategy, which allows states to renew
eligibility onanex parte basis for MAGI and non-MAGI individuals with income at
orbelow100percentoftheFPLwhennodata is returned. This strategy helps reduce
the administrative burden on families and the state, particularly when verifying
complex self-employment income.
CMSalsorecentlygrantedwaiverauthoritytotwostates to extend renewals for children for
upto12months,tosupportretentionforchildren,conductoutreach,andminimizeprocedural
disenrollments of eligible individuals. Other states interested in adoptingthis strategy are
encouraged to contact CMS.
Asof December2023,CMShasapprovednearly400waivers under section 1902(e)(14) of the
Act, but there are many more strategies that states may adopt. States may request authority to
implementoneormoreof thesestrategies by contactingtheir CMS state lead. CMSis available
toprovidetechnicalassistanceandcanprovidesamplelanguagethestatecanuseto craft a letter
requestingthe waiver authority.
b. Partnering with Managed Care Plans
States that deliver services through Medicaid and CHIPmanaged care should consider
partneringwith managed care plans to support coverage retention, particularly for children
enrolledinmanagedcare.Statesarestronglyencouragedto work with managed care plans for
targetedoutreach.Statesmay 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
outreachtofamilieswholostcoverageforproceduralreasons,sothat families may return their
renewalformtohavetheireligibilityreconsidered.Managedcareplanscanalsoutilizemultiple
modalities to reach families (e.g., phone call, email, text). States should have managed care
planspartnerwithpediatriciansandotherchildrensproviderstosupportcoverageretentionand
work with families to maintain enrollment.
Duringunwinding,statesalsohaveexpandedopportunitiestowork with managed care plans
usingstrategies authorizedusingwaiverauthorityundersection1902(e)(14)(A)ofthe Act to:
 Accept updated beneficiary contact information provided by managed care plans
without takingan 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 CHIPrenewal forms.
For more information on how states may work with managed care organizations, states can
reviewCMS StrategicApproachestoEngagingManagedCarePlans to Maximize Continuity Page 14  CMCSInformational Bulletin
of Coverage as States Resume Normal Eligibility and Enrollment Operations.37
c. Providing Continuous Eligibility for Children
Pursuant to the CAA, 2023, beginningJanuary 1, 2024, all states will be required to provide
children enrolled in Medicaid and CHIPwith 12 months of continuous eligibility, even if the
familyexperiences a change in circumstances duringthe year that would otherwise impact the
childs eligibility, such as a change in income or household size.38 Continuous eligibility
promotescontinuityof coverage and helps provide children consistent access to needed health
care services.39 For additional information, see CMSState Health Official Letter (SHO) #23-
004, Section 5112 Requirement for all States to Provide Continuous Eligibility to Children in
Medicaid and CHIPunder 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
Tostreamlineenrollmentandrenewalsforchildren,statesshouldconsider adoptingthe 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 (includingrelated to
income)fromanentitydesignatedbythestateasanExpressLaneAgencytodeterminea childs
eligibility for Medicaid or CHIP.42 States may use this option when determiningeligibility 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
transitioningfromMedicaidtoCHIP,andpremiumsareaknownbarrier both to enrollment and
seamless transitions. 44 To mitigate loss of coverage amongchildren due to failure to pay
37CMS,Strategic ApproachestoEngagingManagedCarePlanstoMaximizeContinuityofCoverageasStatesResumeNormal
EligibilityandEnrollmentOperations,January2023,availableat https://www.medicaid.gov/resources-for-
states/downloads/health-plan-strategy.pdf.
38Section5112oftheCAA(P.L117-328),availableathttps://www.congress.gov/117/bills/hr2617/BILLS-117hr2617enr.pdf.
39ASPE,MedicaidChurningandContinuityofCare:EvidenceandPolicyConsiderationsBeforeandAftertheCOVID-19
Pandemic,April12,2021,availableathttps://aspe.hhs.gov/sites/default/files/private/pdf/265366/medicaid-churning-ib.pdf.
40CMS,SHO #23-004,Section5112RequirementforallStatestoProvideContinuousEligibilitytoChildreninMedicaidand
CHIPundertheConsolidatedAppropriationsAct,2023,September29,2023,availableat
https://www.medicaid.gov/sites/default/files/2023-09/sho23004.pdf.
41Seeforexample,CMSDemonstrationApprovalLetter,OregonHealthPlan,September28,2022,availableat
https://www.oregon.gov/oha/HSD/Medicaid-Policy/Documents/2022-2027-1115-Demonstration-Approval.pdf,andCMS
DemonstrationApprovalLetter,WashingtonMedicaidTransformationProject,April14,2023,availableat
https://www.medicaid.gov/medicaid/section-1115-demonstrations/downloads/wa-stc-ca-04142023.pdf.
42ExpressLaneAgenciesmayincludeSNAP,TANF,SchoolLunch,HeadStart,NationalSchoolLunchProgram,andWomen,
Infants,andChildren,amongothers.Formoreinformationsee,CMS,OpportunitiestoSupportUnwindingEffortsforStates
withIntegratedEligibility Systemsand/orWorkforces,September2022,availableathttps://www.medicaid.gov/resources-for-
states/downloads/opp-unwind-eff-st-integ-elig-sys-workforce.pdf.
43FormoreinformationonExpressLaneEligibilityandSPAtemplates,seeCMSSHO#10-003,ExpressLaneEligibility
Option,February2010,availableathttps://www.medicaid.gov/sites/default/files/Federal-Policy-
Guidance/downloads/SHO10003.PDF.
44MedicaidandCHIP PaymentandAccessCommission,UpdatedAnalysisofChurnandCoverageTransitions,April7,2022,
availableathttps://www.macpac.gov/publication/updated-analyses-of-churn-and-coverage-transitions/. Page 15  CMCSInformational Bulletin
monthlypremiums,statesmayelecttopermanentlyeliminateortemporarily suspend premiums
duringthe unwindingperiod. 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 beingallowed to reenroll in CHIP. Applicable states are encouraged to either eliminate
premiumlock-outperiodspermanentlyorsuspendthispolicyduringtheunwindingperiod.CMS
encourages states that are constrained in their ability to eliminate such cost-sharingto instead
establishaffordableannual enrollment fees rather than collectingmonthly premium payments.
Affordableenrollmentfees 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.
Manystateshaveatieredpremiumstructurebasedonachildshouseholdincome. Upon review
of availabledatasourcesduringanexparterenewal,astatemayfindthat 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 followingpremium
assignment principles:46
 LowerCostPremiumBand: If available data shows the child is eligible for a lower cost
premiumband,thestateshouldmovethechildtothelowercostpremium band and send
a notice to the household informingthem 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
highercostpremiumband,thestateshouldmaintainthechildinthesame premium band
andgivethehouseholdanopportunity to refute the information that was obtained from
datasources.If abeneficiaryprovidesdocumentation/additionalinformation 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,thestateshouldnotterminatecoverage but rather assign the premium band
based on the available data.
f. Modifying Policies for Substitution of Coverage in Separate CHIP
UnlikeMedicaid,separateCHIPrequireschildrentobe uninsured to be eligible for coverage,47
except if a state elects to provide premium assistance through its separate CHIP.48 States with
separateCHIPsarerequiredtousereasonablemethodstoensurethat separate CHIPcoverage is
notsubstitutingforgrouphealthplancoverage.49Onemethodsomestates use to implement this
requirement is applyinga waitingperiod, which is a period of uninsurance (not to exceed 90
45CMS,ProposedRule:StreamliningtheMedicaid,ChildrensHealthInsuranceProgram,andBasicHealthProgram
Application,EligibilityDetermination,Enrollment,andRenewalProcesses,September7,2022,availableat:
https://www.federalregister.gov/documents/2022/09/07/2022-18875/streamlining-the-medicaid-childrens-health-insurance-
program-and-basic-health-program-application.
46CMS,SupportingSeamlessCoverageTransitionsforChildrenMovingBetweenMedicaidandCHIPinSeparateCHIP
States,December12,2022,availableathttps://www.medicaid.gov/resources-for-states/downloads/supporting-medicaid-chip-
transitions.pdf.
47Section2101(a)oftheActand42C.F.R.457.1,457.2and457.10.
48Section2105(c)(10)oftheAct.
4942C.F.R.457.805(a). Page 16  CMCSInformational Bulletin
days) after an individual has disenrolled from group health plan coverage, Medicaid, or CHIP
before they can enroll/re-enroll in CHIP.50 CMSencourages states to eliminate such waiting
periods to reduce potential barriers or delays for otherwise eligible children to enroll in CHIP.
States mayadoptalternativemethodsforaddressingconcernsaboutsubstitution of group health
plan coverage, such as monitoring. Examples of common substitution monitoringstrategies
include addingquestions to health coverage applications about enrollment in private coverage
and conductingdatabase checks to ensure CHIPbeneficiaries do not have other coverage.
g. Delaying Procedural Disenrollments for Children to Enhance Outreach
Oneof thekeystrategiesofferedbyCMSis the state option to delay procedural disenrollments
forbeneficiariesforoneormoremonthswhilethestateconductstargetedrenewaloutreach.This
strategyallowsbeneficiarieswhowouldotherwiselosecoverageforproceduralreasons, such as
failuretoreturnarenewalform,additionaltimetocompletetheirrenewalform or provide other
necessaryinformationandgivesstatesadditionaltimetoconduct outreach. This strategy can be
targeted to specific populations at risk of losingcoverage, includingchildren. This strategy is
available for states to implement throughout the unwindingperiod, or on an ad hoc basis for
cohortsof renewalsbasedoncertaindefinedcriteria(e.g.,if thepercentof anticipatedprocedural
disenrollments exceeds a specified threshold). States must use the additional time to conduct
targeted outreach to encourage beneficiaries to return renewal forms.
States seekingto 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
implementingthisstrategyshouldsendanemailrequestingconcurrence to the CMSunwinding
mailbox (CMSUnwindingSupport@cms.hhs.gov) and note the use of this strategy in their
unwindingplans.
V. Outreachto Families andStrengthening Community Partnerships
Childrenmaylosecoverageif theirparentsorguardiansbelievethey 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
MedicaidorCHIPduetohigherincomethresholdsforchildren.Inaddition,familieswithyoung
childrenenrolledinMedicaidandCHIPmayhaveneverhadtocompletea renewal before (e.g.,
if theirchildwasadeemednewbornand/orif theirchildwasenrolled just before or while the
continuous enrollment condition was in effect).
CMSencourages state Medicaid and CHIPagencies to collaborate with other state agencies
and community partners to ensure families have up-to-date information about the
redetermination processincludingwhat is required to keep children in coverage.
State Medicaid and CHIPagencies can:
5042C.F.R.457.805(b)(2). Page 17  CMCSInformational Bulletin
 Encourageparentsorguardianstofilloutrenewalformsfortheirchildrenwhocannot
be renewed on an ex parte basis, even if the parents or guardians are no longer
eligible.
 Work with other family-facingstate agencies to share up-to-date information about
renewals, and request that they engage directly with families.
 Promote consistent messagingby distributingcommunication materials, such as
flyers, social media graphics, and articles. (Messages and materials specific to
parents/guardiansandchildren may be found on the CMSCommunications Page).51
 Engage community-based organizations to play a role in educatingand informing
families (e.g., Navigators/assisters, hospitals, community health centers, faith-based
organizations and leaders, community centers, youth sports programs, barbershops,
nailsalons,beautysalons and public libraries). Community-based organizations can
engage directly with Medicaid and CHIPfamilies about the importance of renewing
their coverage. These organizations have strongrelationships 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 CHIPrenewals. Schools should use existingmodes of
communication(e.g.,email,text,calls,backpack flyer/postcards) to get the word out
tofamilies.Schoolsshouldalso 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.
 Havemanagedcareplansworkdirectlywithpediatricproviderstotrackrenewaldates
and support families with assistance to fill out renewal forms.
For communication, outreach and education resource materials please see the CMSwebpage,
Medicaid and CHIPRenewals Outreach and Educational Resources.52
VI. Reporting andMonitoring
In March 2022, CMSreleased an UnwindingEligibility and Enrollment Data Reporting
Templatethatstatesmustuseto submit the CMSMonthly UnwindingReport duringa states
unwindingperiodinaccordancewiththeCAA,2023,53 and the guidance released in SHO #22-
001,PromotingContinuityof Coverage and DistributingEligibility and Enrollment Workload
inMedicaid,theChildrensHealthInsuranceProgram(CHIP),andBasicHealthProgram (BHP)
51CMS,MedicaidandCHIPRenewalsOutreachandEducationalResources,availableathttps://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.
52CMS,MedicaidandCHIPRenewalsOutreachandEducationalResources,"availableathttps://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.
53CMS,UnwindingEligibilityandEnrollmentDataReportingTemplate,,available
https://www.medicaid.gov/sites/default/files/2022-03/unwinding-data-rprt.xlsx. Page 18  CMCSInformational Bulletin
UponConclusionof theCOVID-19PublicHealthEmergency.54 The required metrics outlined
in the UnwindingEligibility and Enrollment Data ReportingTemplate are designed to
demonstrate states' progress towards restoringtimely application processingand initiatingand
completingrenewalsof eligibilityfor all Medicaid and CHIPbeneficiaries. In addition to these
unwinding-specific reports, states must also continue to meet existingreportingrequirements,
includingsubmittingtimely data through the Performance Indicator dataset on the 8th of each
calendar month, and data submissions through the T-MSISdataset before the end of the
subsequent calendar month.55 States aggregate reportingfor adults and children through the
PerformanceIndicatordataset, allowingfor more comprehensive Medicaid and CHIPprogram
monitoring. States report T-MSISdata at the individual-level, providingmore granular data on
the impact of unwindingon specific eligibility groups.
CMSis closely monitoringstates data submissions and encourages states to supplement
required federal reportingwith additional state-specific data. Specifically, CMSencourages
states to track, analyze, and report publicly the followingstate-specific metrics duringthe
unwindingperiod:
 Monthly Medicaid/CHIPterminations amongchildren in household units with parents
who were disenrolled from Medicaid/CHIP(to identify opportunities for targeted
outreach).
 Monthly transition outcomes56 between coverage programs, including:
o The number of individuals whose accounts are transferred from Medicaid to
separateCHIP;and,of these,thenumberindividuals who subsequently enroll in
separate CHIP.
o The number of individuals whose accounts are transferred from CHIPto
Medicaid; and, of these, the number of individuals who subsequently enroll in
Medicaid.
Asa bestpractice,state-specificdatamonitoringstrategies should also include a breakdown of
unwindingdata by Medicaid eligibility group, the basis for eligibility (e.g., MAGI vs. non-
MAGI),anddemographiccharacteristics(e.g.,age,race,ethnicity,language).Thissupplemental
dataanalysiswillenablestatestotrackrenewaloutcomesmorecloselyforMedicaid-and CHIP-
enrolled children and deploy targeted strategies to address those outcomes.
CMScontinues to closely monitor changes in Medicaid and CHIPenrollment and is working
directly with states to identify instances where the data indicate individuals may have lost
coverage in violation of the Medicaid or CHIPrenewal requirements.
54CMS,SHO #22-001,PromotingContinuityofCoverageandDistributingEligibilityandEnrollmentWorkloadinMedicaid,
theChildrensHealthInsuranceProgram(CHIP),andBasicHealthProgram(BHP)UponConclusionoftheCOVID-19Public
HealthEmergency,March3,2022,availableathttps://www.medicaid.gov/federal-policy-guidance/downloads/sho22001.pdf.
55CMS,CIB, KeyDatesRelatedtotheMedicaidContinuousEnrollmentConditionProvisionsintheConsolidated
AppropriationsAct,2023,January5,2023,availableat:https://www.medicaid.gov/federal-policy-
guidance/downloads/cib010523.pdf.
56Section5131oftheCAA, 2023requiresstatestoreporttoCMSmonthlydataonthenumberofindividualswhoseaccountsare
receivedbytheMarketplace(orBasicHealthProgram)andrelatedoutcomes(e.g.,qualifiedhealthplaneligibility,selection),
andonthenumberofindividualsenrolledinaseparateCHIP.5131oftheCAA,2023,(P.L117-328)availableat
https://www.congress.gov/117/bills/hr2617/BILLS-117hr2617enr.pdf. Page 19  CMCSInformational Bulletin
As described in SHO #22-001, CMScontinues to monitor states compliance with reporting
requireddataand meetingtimelines related to initiatingand completingrequired eligibility and
enrollment actions duringthe states unwindingperiod.57 Where reported data or other
informationindicatesthatstatesarenotmeetingunwindingtimelinesaslaidoutintheSHO#22-
001andsubsequentguidance,orthatstates have other persistent compliance issues resultingin
erroneous disenrollment of eligible beneficiaries, states may be required to provide additional
data and/or report information more frequently. As described in the CMSSHO #23-002 and
CMS Interimfinalruleontheenforcementof statecompliancewithrequirementsunder section
1902(tt)of theAct,statesthatdonotresolvetheirpendingactionswithinthe timelines specified
mayberequiredtosubmitacorrectiveaction plan to CMSoutliningstrategies and a timeline to
come into compliance with federal requirements.58,59
VII. Closing
Asstatesrestoreroutineeligibilityandenrollmentoperationsduringtheunwindingperiod, CMS
sharesstates goals of ensuringthat eligible children remain enrolled in Medicaid or CHIPand
that children who are no longer eligible transition seamlessly to other coverage options,
includingMarketplace coverage. CMSis committed to providingstates with updated guidance
andresources,asappropriate, as well as ongoingtechnical assistance, to better enable states to
ensure continuity of coverage for Medicaid and CHIPeligible 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 contactingtheir state lead or emailing CMSUnwindingSupport@cms.hhs.gov.
57CMS,SHO #22-001,PromotingContinuityofCoverageandDistributingEligibilityandEnrollmentWorkloadinMedicaid,
theChildrensHealthInsuranceProgram(CHIP),andBasicHealthProgram(BHP)UponConclusionoftheCOVID-19Public
HealthEmergency,March3,2022,availableathttps://www.medicaid.gov/federal-policy-guidance/downloads/sho22001.pdf.
58CMS,SHO #23-002,MedicaidContinuousEnrollmentConditionChanges,ConditionsforReceivingtheFFCRATemporary
FMAPIncrease,ReportingRequirements,andEnforcementProvisionsintheConsolidatedAppropriationsAct,January27,
2023,availableat:https://www.medicaid.gov/federal-policy-guidance/downloads/sho23002.pdf.
59CMS,Medicaid;CMS EnforcementofStateComplianceWith ReportingandFederalMedicaidRenewalRequirementsUnder
Section1902(tt)oftheSocialSecurityAct.December6,2023,availableat:
https://www.federalregister.gov/documents/2023/12/06/2023-26640/medicaid-cms-enforcement-of-state-compliance-with-
reporting-and-federal-medicaid-renewal