CMS Issues Guidance on Six-Month Renewals in Medicaid

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On March 6, CMS issued a regarding the implementation of six-month Medicaid renewals required under H.R. 1 (). Under Section 71101 of H.R. 1, beginning January 1, 2027, individuals eligible for Medicaid expansion coverage must renew their eligibility every six months, twice as frequently as under current law. As outlined in the statute, six-month renewals apply to individuals eligible for Medicaid expansion coverage through a state plan or section 1115 waiver. Per the statute, this provision only applies to state 1115 waivers that cover the entire Medicaid expansion population and does not apply to states with partial expansions (such as Georgia or Wisconsin).

As expected, the guidance largely tracks the statutory requirements in H.R. 1 and underlying regulatory renewal requirements. For example, the guidance reminds states that, consistent with current federal rules, they must first conduct an ex parte review, send a pre-populated renewal form when coverage cannot be renewed based on available data, and provide individuals at least 30 days to respond. The guidance also reminds states that they must continue to provide 12-month renewals (and no more frequently) to other modified adjusted gross income (MAGI) eligibility groups (such as pregnant/postpartum individuals, most children, and parents) as well as American Indian and Alaska Native individuals eligible for expansion. This means that some members of the same household will have different eligibility periods; CMS notes in the guidance that if an individual’s six-month renewal provides information that affects the eligibility of other household members, states must act on that information as a change in circumstances. 

Notably, CMS provides states with two options for when and how to transition to six-month renewal periods. One option allows states to implement the change as individuals come up for their already-scheduled renewals, enabling states to maintain their existing renewal cadence and avoid major operational disruption. This approach is the most administratively feasible and is likely the path most states will take. The alternate option allows states to initiate certain renewals earlier in 2027 in order to shorten existing 12-month certification periods and move individuals more quickly onto a six-month cycle. While this option could accelerate implementation, it would introduce significant additional complexity for state operations and Medicaid enrollees.

These changes apply to all states and D.C. and do not apply to the U.S. territories.

This application of six-month renewal is notably different from the Medicaid work requirements provision, which applies to individuals eligible for Medicaid expansion under the state plan as well as individuals eligible for coverage that qualifies as minimum essential coverage through an 1115 waiver who are between 19-64, not pregnant, and not eligible for Medicare or another Medicaid eligibility group.

For more on H.R. 1, Manatt on Health subscribers can see the Manatt on Health .

See 42 C.F.R. § 435.916 (2023). Section 71102 of H.R. 1 imposed a moratorium prohibiting CMS from implementing certain provisions in the “Medicaid Program; Streamlining the Medicaid, Children’s Health Insurance Program, and Basic Health Program Application, Eligibility Determination, Enrollment, and Renewal Processes,” 89 Fed. Reg. 22780 (April 2, 2024) (the “”). Consistent with this moratorium, prior longstanding federal regulations will apply. In the SMDL, CMS refers to the renewal requirements at 42 C.F.R. § 435.916 in effect as of 2023, available .

For more details on the SMDL, Manatt on Health subscribers can see the Manatt on Health

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