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 December 11, 2024, CMS has approved a number of 1902(e)(14)(A) waivers in relation to unwinding related challenges that states face. These include:
- Strategies to Increase Ex Parte Renewal Rates
- Strategies to Support Enrollees with Renewal Form Submission or Completion to Reduce Procedural Terminations
- Strategies to Update Contact Information
- Strategies to Facilitate Reinstatement of Eligible Individuals for Procedural Reasons
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, including strategies that will support compliance with federal renewal requirements following the end of the Families First Coronavirus Response Act (FFCRA) Medicaid continuous enrollment condition. States that have opted for these strategies, including through mitigation plans, are included under the “Other” categories in the table below.
For additional information on 1902(e)(14)(A) waivers and other strategies to prevent procedural terminations, see SHO letter #22-001 and State Strategies to Prevent Procedural Terminations. Please note that this chart represents unwinding strategies approved under section 1902(e)(14)(A) authority and is not an exhaustive list of strategies a state has otherwise adopted to protect beneficiaries.
The graphic and table below outline the section 1902(e)(14)(A) waivers CMS has approved for states and territories to support the unwinding period, as of December 11, 2024*:
SVG Map
| States/Territories | States/Territories Totals | Strategies to Increase Ex Parte Renewal Rates | Strategies to Support Enrollees with Renewal Form Submission or Completion to Reduce Procedural Terminations | Strategies to Update Contact Information | Strategies to Facilitate Reinstatement of Eligible Individuals for Procedural Reasons | Other Strategies |
|---|---|---|---|---|---|---|
| Alabama | 6 | 5 | 1 | 0 | 0 | 0 |
| Alaska | 10 | 6 | 2 | 1 | 1 | 0 |
| Arizona | 9 | 5 | 1 | 2 | 0 | 1 |
| Arkansas | 6 | 2 | 1 | 3 | 0 | 0 |
| California | 14 | 8 | 0 | 3 | 1 | 2 |
| Colorado | 8 | 4 | 1 | 1 | 1 | 1 |
| Connecticut | 5 | 2 | 1 | 1 | 0 | 1 |
| Delaware | 8 | 4 | 0 | 1 | 2 | 1 |
| District of Columbia | 12 | 4 | 1 | 4 | 2 | 1 |
| Florida | 0 | 0 | 0 | 0 | 0 | 0 |
| Georgia | 7 | 4 | 0 | 2 | 0 | 1 |
| Hawaii | 13 | 8 | 1 | 2 | 1 | 1 |
| Idaho | 3 | 2 | 0 | 1 | 0 | 0 |
| Illinois | 5 | 2 | 0 | 2 | 0 | 1 |
| Indiana | 15 | 8 | 1 | 3 | 2 | 1 |
| Iowa | 2 | 0 | 0 | 2 | 0 | 0 |
| Kansas | 8 | 3 | 2 | 2 | 1 | 0 |
| Kentucky | 14 | 8 | 2 | 1 | 2 | 1 |
| Louisiana | 9 | 4 | 0 | 4 | 0 | 1 |
| Maine | 10 | 6 | 0 | 2 | 1 | 1 |
| Maryland | 11 | 7 | 3 | 0 | 0 | 1 |
| Massachusetts | 9 | 2 | 2 | 4 | 1 | 0 |
| Michigan | 12 | 6 | 1 | 2 | 2 | 1 |
| Minnesota | 14 | 9 | 1 | 2 | 0 | 2 |
| Mississippi | 6 | 3 | 1 | 2 | 0 | 0 |
| Missouri | 8 | 4 | 0 | 2 | 1 | 1 |
| Montana | 3 | 3 | 0 | 0 | 0 | 0 |
| Nebraska | 3 | 2 | 0 | 1 | 0 | 0 |
| Nevada | 13 | 7 | 3 | 2 | 0 | 1 |
| New Hampshire | 4 | 3 | 0 | 0 | 1 | 0 |
| New Jersey | 9 | 5 | 0 | 2 | 0 | 2 |
| New Mexico | 14 | 6 | 3 | 2 | 2 | 1 |
| New York | 10 | 7 | 0 | 2 | 0 | 1 |
| North Carolina | 11 | 7 | 0 | 1 | 2 | 1 |
| North Dakota | 10 | 5 | 1 | 3 | 0 | 1 |
| Ohio | 7 | 3 | 1 | 2 | 0 | 1 |
| Oklahoma | 3 | 1 | 0 | 1 | 0 | 1 |
| Oregon | 5 | 2 | 0 | 3 | 0 | 0 |
| Pennsylvania | 3 | 2 | 0 | 1 | 0 | 0 |
| Puerto Rico | 4 | 0 | 2 | 1 | 0 | 1 |
| Rhode Island | 4 | 1 | 1 | 1 | 0 | 1 |
| South Carolina | 13 | 6 | 3 | 2 | 2 | 0 |
| South Dakota | 1 | 1 | 0 | 0 | 0 | 0 |
| Tennessee | 15 | 9 | 2 | 2 | 1 | 1 |
| Texas | 4 | 1 | 1 | 2 | 0 | 0 |
| Utah | 8 | 3 | 2 | 2 | 0 | 1 |
| USVI | 1 | 1 | 0 | 0 | 0 | 0 |
| Vermont | 9 | 7 | 1 | 1 | 0 | 0 |
| Virginia | 10 | 2 | 2 | 4 | 1 | 1 |
| Washington | 5 | 2 | 1 | 2 | 0 | 0 |
| West Virginia | 4 | 1 | 2 | 0 | 0 | 1 |
| Wisconsin | 2 | 1 | 0 | 1 | 0 | 0 |
| Wyoming | 6 | 2 | 0 | 1 | 1 | 2 |
| Total Waivers by Type | 206 | 47 | 88 | 28 | 36 | |
| Total Approved Waivers | 405 | |||||
| Total States/Territories with Waivers | 52 |
* Download the full section 1902(e)(14)(A) waiver dataset here.