CMS Final Rule Aims To Streamline Application, Renewal Processes for Medicaid, CHIP

(Original post published September 8, 2022)

On March 27, the Centers for Medicare and Medicaid Services issued a final rule to streamline the application and renewal processes for Medicaid and the Children’s Health Insurance Program (CHIP). As of November 2023, Arkansas had 754,560 Medicaid enrollees and 38,251 CHIP enrollees with comprehensive coverage.

The rule includes numerous provisions aimed at standardizing and simplifying enrollment and renewal processes nationwide. It is intended to address current Medicaid and CHIP policies that can contribute to coverage disruptions and churn, the temporary loss of coverage that occurs when beneficiaries lose coverage and then re-enroll in a short time frame. For example, the rule bars states from conducting renewal assessments more than once every 12 months, which a few states have been doing for some beneficiaries.

The rule also requires states to provide all individuals with at least 15 days to provide any additional information when initially applying for coverage and 30 days to respond to information requests regarding renewal of coverage. The rule also eliminates any in-person interview requirements for applicants with non-income-based eligibility (e.g., individuals who are 65 and older or have blindness or a disability) and provides a minimum 90-day reconsideration period if enrollees lose coverage for not providing information needed to redetermine eligibility.

For children enrolled in CHIP, the rule allows enrollees to remain in the program or re-enroll without a lockout period if premiums are not paid. There are 12 states that impose lockout periods following non-payment, with 10 of those states applying a maximum 90-day lockout period. Arkansas does not charge premiums within CHIP, although it does have cost-sharing requirements for CHIP enrollees with household incomes above a certain level.

The rule also prohibits annual or lifetime limits on benefits for CHIP beneficiaries. As noted in the rule, 13 states place either an annual or lifetime dollar limit on at least one CHIP benefit. One of those states is Arkansas, which places an annual limit of $500 on durable medical equipment. The rule also eliminates the state option to impose a waiting period for families with children eligible for CHIP who were recently enrolled in a group health plan. Arkansas is one of nine states that impose a waiting period, currently at 90 days.

The rule also addresses some of the key factors which led to nearly 19 million Medicaid beneficiaries being disenrolled during the Medicaid “unwinding,” when states resumed Medicaid eligibility determinations following the end of the pandemic-related continuous coverage requirement. Among states with publicly available data, 70% of disenrollments were procedural, meaning that enrollees were disenrolled because they did not complete the renewal process. In Arkansas, 77% of disenrollments were procedural. There are many factors that could lead to a procedural disenrollment, including outdated contact information or an enrollee not understanding what additional information is needed from the state to complete the renewal process.

ACHI President and CEO Dr. Joe Thompson and ACHI Health Policy Director Craig Wilson wrote about Arkansas’s experience as the second state to complete the redetermination process in an article for Health Affairs. Find additional resources on our Arkansas Medicaid topic page.