As a result of the COVID pandemic and Public Health Emergency (“PHE”), Congress enacted legislation requiring states claiming an increase in the Federal Medical Assistance Percentage (“FMAP”) to implement continuous enrollment. States claiming the temporary 6.2 percentage point increase in the FMAP have not been permitted to terminate enrollment for most individuals enrolled in Medicaid since March 18, 2020.
Continuous enrollment resulted in state agencies implementing an “auto-renewal” process for Medicaid beneficiaries instead of the yearly renewal/redetermination of benefits. The continuous enrollment requirement for states will end on March 31, 2023.
Beginning April 1, 2023, states can terminate Medicaid enrollment for individuals who no longer qualify for Medicaid after conducting a renewal/redetermination. Enrollees will be given proper notice, and each state has determined its own timeline for beginning this process. Below is a link to a chart including anticipated state timelines for states ending the auto-renewal process. https://www.medicaid.gov/resources-for-states/downloads/ant-2023-time-init-unwin-reltd-ren-02242023.pdf
In addition to promptly responding to Medicaid renewal forms, we recommend that facility trust accounts be audited for fund accumulation to avoid any surprises concerning excess resources that must be spent down. Particular attention should be paid to residents who have experienced a loss of capacity and cannot assist with the process.
If you have any questions regarding the new legislation, your state’s renewal/redetermination process, or concerns with specific residents, please reach out to us! We are happy to assist.
