The Centers for Medicare & Medicaid Services (CMS) has released sub-regulatory guidance and tools to support state Medicaid and Children’s Health Insurance Program (CHIP) agencies in returning to normal eligibility operations once the unwinding period begins. The updated August 2021 guidance lays out a timeline of “up to 12 months” for completing pending renewals and redeterminations for changes in circumstances. This CMS “punch list” includes operational and policy strategies for states to maintain continuity of coverage, and this CMS issue brief highlights ways to improve outreach, enrollment, and renewal activities to ensure eligible individuals are able to enroll in and retain their health coverage.

People of color are overrepresented in the Medicaid program and are more likely to experience volatility and instability in employment and housing as a result of longstanding, structural racism, thus increasing the chances that these individuals could lose coverage for administrative reasons when the continuous coverage requirement ends. States therefore have a clear imperative to center health equity as they plan for the end of the continuous coverage requirement.

To ensure eligible individuals don’t churn off coverage once the continuous coverage requirement ends, states can take steps to improve consumer communications, partner with stakeholders, and ensure Medicaid/Marketplace coordination.

States can also strengthen eligibility and enrollment processes and implement information technology (IT) system, policy, and operational strategies to update contact information to ensure eligible enrollees are able to keep or transition to new affordable health coverage.

From February 2020 through November 2021, the median state among the 29 states with available data saw a total Medicaid enrollment growth of 23.2 percent, with the average state seeing monthly growth well above previous levels.