During a CMS National Stakeholder call, the omnibus spending plans were discussed as it relates to the recent spending plan proposed by Congress that would allow states to resume Medicaid continuous enrollment unwinding after the end of the first quarter of 2023. This post outlines a few key points about the unwinding of the Medicaid continuous enrollment requirement and the associated provisions in the bipartisan spending plan.

The proposed law makes it clear that states can take up to a full year to initiate all renewals. CMS has previously issued guidance allowing states up to 14 months to resume routine eligibility and enrollment processes; 12 months to initiate renewals and an additional two months to complete the process.

Extended federal funding will help states avoid the fiscal cliff. In the first quarter of 2023, states will continue to receive the 6.2 percentage point increase in the Federal Medical Assistance Percentage (FMAP). The increased FMAP is phased down for the remaining quarters in 2023 for states that meet requirements.

In order to qualify for the ongoing FMAP bump, states must meet certain maintenance of effort requirements, including using the temporary Section 1902(e(14)(A) flexibilities to smooth out the unwinding and avoid procedural un-enrollments or other processes and procedures approved by CMS. States must also meet specific data reporting requirements.

States must make a good-faith effort to locate enrollees for whom mail has been returned. Attempts must be made to ensure that it has up-to-date contact information using the National Change of Address Database Maintained by the United State Postal Service, other public program information, or other reliable sources of contact information. Additionally, the state may not disenroll anyone on the basis of returned mail until the state has made a good-faith effort to contact the individual using more than one communication mode.

Congress establishes state unwinding data reporting requirements and establishes penalties for non-compliance. If a state does not meet specific reporting requirements, it will be penalized with a reduction in its FMAP. Furthermore, CMS guidelines have been given additional authority to hold states.

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