CMS Issues Guidance on Medicaid Eligibility Determinations

From our national partners at ANCOR:

The Centers for Medicare & Medicaid Services (CMS) released guidance on the implementation of the Medicaid eligibility-related requirements from last year’s budget reconciliation legislation that, among other things, requires states to verify the eligibility of beneficiaries in the Medicaid expansion population every six months beginning January 1, 2027.

In this guidance letter, CMS provides a summary of the eligibility changes required by the new law along with the following direction and clarification to states in the implementation of these new requirements:

• A reminder for states that, as they begin conducting six-month renewal activities, they will also need to ensure beneficiary compliance with Medicaid work and community engagement requirements;
• A description of different options, along with illustrative examples, for states to consider in implementing six-month eligibility redeterminations for both new and existing beneficiaries;
• How states should treat households with different renewal schedules, movement between eligibility groups at the time of renewal, and coordination with recertifications or reviews for other government-funded programs, such as the Supplemental Nutrition Assistance Program (SNAP); and
• Directions for states to submit a state plan amendment (SPA) no later than March 31, 2027, to reflect compliance with the new eligibility redetermination requirements.

For additional information about the 2025 budget reconciliation law, please visit CMS’s technical assistance and guidance website as well as ANCOR’s Medicaid Resource Center.