New CMS Guidance on Unwinding Provisions in the CAA, 2023

Support for this issue brief was provided by the State Health and Value Strategies program, a grantee of the Robert Wood Johnson Foundation. The views expressed here do not necessarily reflect the views of the Foundation.

On January 27, 2023, the Centers for Medicare & Medicaid Services (CMS) released a State Health Official (SHO) letter, “Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.”

This SHO letter is the second in a series of guidance related to Section 5131 of the Consolidated Appropriations Act, 2023 (CAA), which established a fixed end date for the Medicaid continuous coverage requirement, a gradual phasedown for the enhanced federal match and new guardrails for mitigating coverage loss for individuals who continue to be eligible. The SHO letter builds on CMS’ first CAA unwinding-related guidance, which focused on the key dates when states can commence and complete the processing of their pending renewals.

In an expert perspective prepared for the Robert Wood Johnson Foundation’s State Health and Value Strategies program, Manatt Health summarizes the guidance provided in the SHO letter and discusses expectations for states as they finalize their policy and operational plans for unwinding the Medicaid continuous coverage requirement.

To read the full expert perspective, click here.



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