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COVID-19 PHE Unwinding Section 1902(e)(14)(A) Waiver Approvals

Following the end of the COVID-19 Public Health Emergency (PHE), many states will need to process an unprecedented volume of renewals and application determinations on a timely basis. This substantial volume of eligibility caseload work, coupled with significant staffing shortages, could cause many states to face substantial operational and system challenges. To support states facing significant operational issues with income and eligibility determination systems and to protect eligible beneficiaries from inappropriate coverage losses during the unwinding period following the end of the COVID-19 PHE, the Centers for Medicare & Medicaid Services (CMS) is providing states the option to request authority under section 1902(e)(14)(A) of the Social Security Act (the Act) in limited circumstances and subject to CMS approval.

As outlined in the March 3, 2022 State Health Official (SHO) letter #22-001, states may request time-limited authority under section 1902(e)(14)(A) of the Act to pursue strategies to support the unwinding period following the end of the COVID-19 PHE that facilitate the renewal process and ensure due process protections during the fair hearing process.

As of September 6, 2022, CMS has approved the following strategies under section 1902(e)(14)(A) of the Act. For additional details on these strategies, please see SHO letter #22-001.

  • Renewal for Individuals Based on Supplemental Nutritional Assistance Program (SNAP) Eligibility (Targeted SNAP Renewal)
  • Ex Parte Renewal for Individuals with No Income and No Data Returned (Beneficiaries with No Income Renewal)
  • Facilitating Renewal for Individuals with no Asset Verification System (AVS) Data Returned within a Reasonable Timeframe (Streamlined Asset Verification)
  • Partnering with Managed Care Plans to Update Beneficiary Contact Information (MCO Beneficiary Contact Updates)
  • Use of the National Change of Address Database (NCOA) and United States Postal Service (USPS) Returned Mail to Update Beneficiary Contact Information (NCOA and/or USPS Contact Updates)
  • Extending Automatic Reenrollment into Medicaid Managed Care Plans up to 120 Days (MCO Plan Auto-Reenrollment)
  • Extended Timeframe to Take Final Administrative Action on Fair Hearing Requests (Fair Hearing Timeframe Extension)
  • Delaying the Resumption of Premiums Until a Full Redetermination is Completed (Premium Resumption Delay)

States may also request authority under section 1902(e)(14)(A) of the Act to implement other strategies needed to ensure that they can establish income and eligibility determination and operations systems that protect beneficiaries during the unwinding period, and some states have done so. These are included under “Other” in the table below.

The table below outlines the section 1902(e)(14)(A) waivers CMS has approved for states to support the unwinding period:

States  Targeted SNAP Renewal Beneficiaries with No Income Renewal Streamlining Asset Verification MCO Beneficiary Contact Updates  NCOA and/or USPS Contact Updates  MCO Plan Auto-Reenrollment  Fair Hearing Timeframe Extension  Premium Resumption Delay Other State Totals
Alabama X X X X1 4
Alaska
Arizona X X X X X 5
Arkansas X 1
California X X X 3
Colorado X 1
Connecticut
Delaware X X X 3
District of Columbia X X X X 4
Florida
Georgia
Hawaii X X X X 4
Idaho
Illinois X X X X 4
Indiana
Iowa X 1
Kansas X X X 3
Kentucky X X X X X X 6
Louisiana X X X X X 5
Maine
Maryland X 1
Massachusetts
Michigan
Minnesota X 1
Mississippi
Missouri X X X X X X 6
Montana
Nebraska
Nevada X X X 3
New Hampshire X X 2
New Jersey X X X 3
New Mexico X X X X X 5
New York
North Carolina
North Dakota
Ohio X X X X 4
Oklahoma
Oregon X 1
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee X2 X X X 4
Texas X X 2
Utah
Vermont X X X X 4
Virginia X X X 3
Washington
West Virginia
Wisconsin
Wyoming X 1
Total waivers by type 8 19 13 19 12 4 8 1
Total Approved Waivers 84
Total States with Waivers 27

* indicates Other approval
1Alabama has an approved Section 1902(e)(14)(A) waiver to use TANF income information to determine income eligibility for Medicaid, similar to the approved SNAP strategy. 
2Tennessee- has an approved Section 1902(e)(14)(A) waiver that authorizes the state to apply the “Targeted SNAP Renewal” strategy to select non-MAGI eligibility groups.