Tim Sohosky • March 10, 2026

CMS Issues Guidance on Medicaid Eligibility Determinations

Author

Tim Sohosky

Date

March 10, 2026

Share

THIS IS PORTAL AUTHENTICATOR WIDGET. THIS WON'T BE VISIBLE ON PUBLISHED PAGE.

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.

< Previous Post

Next Post >
PA ODP logo with dark blue border

ODP Updates the MAAC on Paid Relative Caregiving & Travel Limitations

By Tim Sohosky • May 29, 2026
On Thursday, May 28, the Office of Developmental Programs (ODP) provided an update to the Medical Assistance Advisory Committee (MAAC) regarding current policies and upcoming regulatory changes following a recent Commonwealth Court decision. On February 17, 2026, the PA Commonwealth Court issued a decision in Dunkelberger v. Department of Human Services that determined that ODP’s limitations on provider model services (specifically the 40/60-hour caps and 90-day travel maximums) were null and void. The decision was based on process rather than policy validity; the Court found that these limitations were not properly promulgated as regulations in accordance with the Commonwealth Documents Law and Regulatory Review Act. To maintain a balanced approach between flexibility and oversight, ODP is moving forward with the following actions: Regulatory Amendments: ODP will amend regulations to establish formal authority for setting service delivery limits that support individual welfare and program integrity. Self-Directed Model Agreements: ODP has already modified agreements for self-directed models to clarify limits on overtime, combined relative service provision, and travel restrictions. Travel Restrictions: Due to the inability to monitor services effectively over long distances, service provision will now be limited to Pennsylvania and contiguous states. Waiver Changes: ODP will seek modifications through the amendment process to the Consolidated, P/FDS, Community Living, and Adult Autism Waivers to include: New requirements for agencies providing IHCS and Companion services to disclose a DSP's relationship to participants; and Strengthened programmatic oversight and integrity measures. Life Sharing Alternative: For participants requiring more than 60 hours of paid care from a relative, the Life Sharing (24/7) service model remains the recommended alternative. ODP anticipates a public comment period for these proposed waiver changes beginning in January 2027.
Two men with intellectual disabilities working happily on a tablet.

Shapiro Administration's Strategic Investments in ID/A Community Lead to Highest Number of Pennsylvanians Ever Served in HCBS

By Tim Sohosky • May 28, 2026
Press Release from DHS : Published May 27, 2026
Yellow screen with the words

ODP Provides Updates to PBC 2026/27 Residential Pay-for-Performance

By Cathy Barrick • May 28, 2026
The Office of Developmental Programs (ODP) has shared ODPANN 26-039 . The purpose of this communication is to provide updated details about the Residential Performance-Based Contracting (PBC) Pay-for-Performance (P4P) initiatives for Fiscal Year 2026/27. Updates are provided in red . Please review the announcement for more details. Visit here to access the Pay for Performance (P4P): Residential Rural Capacity Expansion Plan template .