State Option to Delay Procedural Disenrollments

The March 31, 2023 expiration of the continuous enrollment condition authorized by the Families First Coronavirus Response Act (FFCRA) triggered the start of states’ return to routine processing of Medicaid renewals. As part of the Centers for Medicare & Medicaid Services’ (CMS) ongoing efforts to support states and protect eligible beneficiaries from inappropriate coverage losses during the return to routine Medicaid renewals period, CMS released State Strategies to Prevent Procedural Terminations, that provides information on strategies to prevent procedural disenrollments.

One of the key strategies offered by CMS is the state option to delay procedural disenrollments for beneficiaries for one or more months while the state conducts 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 complete their renewal form or other necessary information and provides states with additional time to conduct outreach. This strategy is available for states to implement throughout the return to routine Medicaid renewals period, or on an ad hoc basis for cohorts of renewals based on certain defined criteria (e.g., if the percent of anticipated procedural disenrollments exceeds a specified threshold). States must use the additional time to conduct targeted outreach to encourage beneficiaries to return renewal forms.

States seeking to elect this strategy should request concurrence for an exception to timely determinations of eligibility per regulations at 42 CFR 435.912(e). States interested in implementing this strategy should send an email requesting concurrence to the CMS unwinding mailbox and note the use of this strategy in their unwinding plans.

The chart below identifies states that requested concurrence to delay procedural disenrollments for beneficiaries during the return to routine Medicaid renewals period, including information on the number of months for the delay, the duration of the authority, and affected populations. This chart only identifies states that have opted to pause procedural disenrollments to allow time for targeted outreach. It does not identify states that received CMS approval to delay procedural disenrollments as part of a mitigation strategy (that is, a strategy the state adopted to address areas of non-compliance with Medicaid renewal requirements). The chart below reflects information as of April 19, 2024.

¹ Colorado is delaying procedural disenrollments for a subset of the non-MAGI population (long term care populations)

² Illinois is delaying action on procedural disenrollments for two months for a cohort that would have originally been due in June 2023.

³ Kentucky is delaying procedural disenrollments for a subset of the non-MAGI population (long term care populations) for two months beginning with renewals that would have been due May 2023 through August 2023. The state is delaying procedural disenrollments for a subset of the non-MAGI population (long term care populations) for three months beginning with renewals that would have been due September 2023 through the end of unwinding. The state is delaying procedural disenrollments for one month for all other beneficiaries starting with renewals that would have been due in September 2023 through the end of unwinding.

⁴ New Hampshire is delaying procedural disenrollments for a subset of the non-MAGI population (long term care populations) for one month for renewals that would have been due in August 2023 and September 2023. The state is delaying procedural disenrollments for a subset of the non-MAGI population (long term care populations) for two months beginning with renewals that would have been due October 2023 through the end of unwinding.

⁵ South Carolina will delay procedural disenrollments for any month in which the renewal form return rate is under 50%