CMS issues guidance on six-month Medicaid renewals

Key Takeaways

On March 6, the Centers for Medicare & Medicaid Services (CMS) released a letter to State Medicaid Directors with implementation guidance on six-month Medicaid renewals required under H.R. 1. Previously renewed once a year, beginning on January 1, 2027, states will be required to complete eligibility redetermination once every six months, or twice a year, for adults eligible for Medicaid expansion coverage.  

What’s in the guidance?

CMS’ guidance provides clarifications for implementing this policy change, including the following key points:

• Eligible populations: Individuals subject to the six-month renewal process include adults enrolled in the Medicaid expansion group and individuals receiving equivalent coverage under Section 1115 waivers that provide coverage comparable to the expansion population.
• Exempt populations: Indigenous populations, individuals in other Modified Adjusted Gross Income (MAGI) based Medicaid eligibility groups (such as children and pregnant women) and individuals in non-MAGI eligibility groups (such as those qualifying based on disability) are exempt from the policy change and will continue to undergo annual renewals.
• Renewal process remains the same: While the frequency of renewals will change, the existing renewal process remains in place. States must continue to attempt automatic renewals using available data sources before requesting additional information from beneficiaries.
• Work and community engagement requirements: The guidance also notes that many adults subject to the six-month renewal cycle may also be impacted by new community engagement requirements and that there is not full alignment between those that are exempt from community engagement requirements and those exempt from the more frequent eligibility verification requirement. States will need to assess both eligibility and compliance with these requirements at renewal.
• Transitioning to six-month renewals: Since the frequency change will impact state operations and workloads, CMS encourages states to begin planning now. States will also be required to submit a State Plan Amendment (SPA) by March 31, 2027, to confirm that they will conduct six-month renewals. More SPA guidance to come.

CMS also outlines two options for states to transition current enrollees to the six-month renewal cycle. States may either adjust existing renewal schedules to move individuals onto a six-month cadence as soon as possible in 2027, or transition individuals at their next scheduled renewal during 2027. States will need to weigh operational considerations when selecting an approach.

Impact on counties

As local health service providers, counties that administer or support Medicaid eligibility and enrollment will likely see an increase in administrative burden due to more frequent Medicaid renewals. This includes processing a higher volume of eligibility determinations, notices to beneficiaries, follow-up documentation and related administrative costs.  

Additionally, counties will likely need to coordinate more frequently with state agencies to ensure eligible residents maintain coverage while complying with new federal requirements.

NACo will continue to provide updates on implementation guidance as more information becomes available and will work with federal partners to ensure counties have the tools and resources needed to support effective implementation.

Read full CMS guidance here