Unwinding and Returning to Regular Operations after COVID-19

The expiration of the continuous enrollment condition authorized by the Families First Coronavirus Response Act (FFCRA) presents the single largest health coverage transition event since the first open enrollment period of the Affordable Care Act. As a condition of receiving a temporary 6.2 percentage point Federal Medical Assistance Percentage (FMAP) increase under the FFCRA, states were required to maintain enrollment of nearly all Medicaid enrollees during the COVID-19 Public Health Emergency.

The Consolidated Appropriations Act, 2023, delinked the end of the FFCRA’s Medicaid continuous enrollment condition from the end of the COVID-19 Public Health Emergency. As a result, the Medicaid continuous enrollment condition will end on March 31, 2023. States will soon resume normal operations, including restarting full Medicaid and CHIP eligibility renewals and terminations of coverage for individuals who are no longer eligible. Beginning April 1, 2023, states are able to terminate Medicaid enrollment for individuals no longer eligible. States will have up to 12 months to return to normal eligibility and enrollment operations.

For more information about the resumption of Medicaid renewals, read: 

• CMS Fact Sheet: Keeping People Covered As States Restart Routine Medicaid Renewals
• CMS Fact Sheet: How You Can Take Action
• CMS Fact Sheet: Monitoring, Oversight, and Assistance to Improve State Systems and Ensure States Meet Federal Requirements

CMS will continue to update this page as additional tools and resources are released.

Guidance (SHOs, CIBs, and FAQs)

• CIB: Basic Requirements for Conducting Ex Parte Renewals of Medicaid and CHIP Eligibility (Posted 11/26/2024)
• CIB: Financial Eligibility Verification Requirements and Flexibilities (Posted 11/20/2024)
• CIB: Use of Unwinding-Related Strategies to Support Long-Term Improvements to State Medicaid Eligibility and Enrollment Processes (Posted 11/14/2024)
• CIB: Notice of Technology and Process Upgrades for Account Transfer Functionality for States Served by Marketplaces on the Federal Platform
• CIB: State Compliance with Medicaid and CHIP Renewal Requirements by December 31, 2026 (Posted 9/20/2024)
• CIB: Guidelines for Achieving Compliance with Medicaid and CHIP Eligibility Renewal Timeliness Requirements Following the Medicaid and CHIP Unwinding Period (Posted 8/29/2024)
• CIB: Ensuring Continuity of Coverage for Individuals Receiving Home and Community-Based Services (Posted 8/19/2024)
• SHO: Continuation of Certain Medicaid and CHIP Eligibility Processing Data Reporting (Posted 5/30/2024)
• CIB: Ensuring Timely and Accurate Medicaid and CHIP Eligibility Determinations at Application (Posted 5/09/2024)
• CIB: Extension of Temporary Unwinding Related Flexibilities (Posted 5/09/2024)
• CIB: Conducting Medicaid and CHIP Renewals During the Unwinding Period and Beyond: Essential Reminders (Posted 3/15/2024)
• Slide Deck: Illustrative Examples of Processes Not Permitted Under Medicaid and CHIP Renewal Requirements (Posted 3/15/2024)
• Ensuring Eligible Children Maintain Medicaid and Children’s Health Insurance Program Coverage (Posted 12/18/2023)
• Frequently Asked Questions to Support the Return to Normal Eligibility Operations for Transitional Medical Assistance and Medical Support (Posted 11/22/2023)
• Extension of 1915(c) Home and Community-Based Services Waiver Appendix K Expiration Dates (Posted 08/02/2023)
• FMAP Reduction for Failure to Meet Reporting Requirements under Section 1902(tt)(1) of the Social Security Act FAQs for State Medicaid and CHIP Agencies (Posted 06/30/2023)
• Letter to U.S. Governors from HHS Secretary Xavier Becerra on Medicaid Redeterminations (Posted 06/12/2023)
• End of the Medicaid Continuous Enrollment Condition Frequently Asked Questions for State Medicaid and CHIP Agencies (Posted 05/12/2023)
• Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023 (Posted 01/31/2023)
• Medicaid Continuous Enrollment Requirement Provisions in the Consolidated Appropriations Act, 2023 (Posted 01/05/2023)
• COVID-19 Public Health Emergency Unwinding Frequently Asked Questions for State Medicaid and CHIP Agencies (Posted 10/17/2022)
• Ending Coverage in the Optional COVID-19 Group: Preparing States for the End of the Public Health Emergency (Posted 10/17/2022)
• Promoting Continuity of Coverage and Distributing Eligibility and Enrollment Workload in Medicaid, the Children’s Health Insurance Program (CHIP), and Basic Health Program (BHP) Upon Conclusion of the COVID-19 Public Health Emergency (Posted 3/3/2022)
• Updated Guidance Related to Planning for the Resumption of Normal State Medicaid, Children’s Health Insurance Program (CHIP), and Basic Health Program (BHP) Operations Upon Conclusion of the COVID-19 Public Health Emergency (Posted 8/13/2021)
• State Health Office Letter: Planning for the Resumption of Normal State Medicaid, Children’s Health Insurance Program (CHIP), and Basic Health Program (BHP) Operations Upon Conclusion of the COVID-19 Public Health Emergency (Posted 12/22/2020)

Section 1902(e)(14)(A) Waivers and Other Strategies

• State Strategies to Minimize Terminations for Procedural Reasons During the COVID-19 Unwinding Period: Operational Considerations for Implementation (Posted 12/18/2023)
• Summary of State Mitigation Strategies for Complying with Medicaid Renewal Requirements
• Strategies to Prevent Procedural Terminations
• COVID-19 PHE Unwinding Section 1902(e)(14)(A) Waiver Approvals
• State Option to Delay Procedural Disenrollments

Data Reporting

• Medicaid & CHIP Leavers and Coverage Transitions: By Eligibility Category and Home & Community-Based Services (HCBS) 1915(c) Waiver Enrollment (Posted 11/27/2024)
• Medicaid Unwinding Child/Youth Data Snapshot (Posted 12/18/2023)
• Medicaid Unwinding Enrollment Trends Data Snapshot as of September 2023 (Posted 12/18/2023)
• COVID-19 Continuous Enrollment Condition Data Reporting

Policy & Operational Resources

Renewals, Redeterminations, and Other Program Requirements

• Slide Deck: Basic Requirements for Conducting Ex Parte Renewals of Medicaid and CHIP Eligibility (Posted 12/05/2024)
• Slide Deck: Financial Eligibility Verification Requirements and Flexibilities (Posted 11/20/2024)
• Slide Deck: Use of Unwinding-Related Strategies to Support Long-Term Improvements to State Medicaid Eligibility and Enrollment Processes (Posted 11/14/2024)
• Slide Deck: Overview of Medicaid and CHIP Eligibility Renewals (Posted 9/20/2024)
• Slide Deck: Temporary Strategies and Ongoing Practices to Support Timely Medicaid and CHIP Renewal Initiation and Processing, August 2024 (Posted 8/29/2024)
• Slide Deck: Ensuring Timely and Accurate Medicaid and CHIP Eligibility Determinations at Application (Posted 5/09/2024)
• Slide Deck: Transitioning Individuals Within Medicaid Eligibility Groups and Between Medicaid and CHIP at Renewal (Posted 12/18/2023)
• Notice Considerations for Conducting Medicaid & CHIP Renewals at the Individual Level (Posted November 7, 2023)
• Scenarios: The Intersection of Continuous Eligibility and Individual Level Renewal Processes (Posted October 18, 2023)
• Preliminary Overview of State Assessments Regarding Compliance with Medicaid and CHIP Automatic Renewal Requirements at the Individual Level (Posted September 21, 2023)
• State Letter: Ensuring Compliance with Requirements to Conduct Medicaid and CHIP Renewal Requirements at the Individual Level (Posted August 30, 2023)
• Mitigation Plan Template for Ex Parte Renewal Compliance Issues (Posted August 30, 2023)
• Resources to Support State Implementation of Renewal Mitigation Strategies (Posted March 23, 2023)
• Ensuring Continuity of Coverage and Preventing Inappropriate Terminations – Part 2 (Posted August 2021)
• Ensuring Continuity of Coverage and Preventing Inappropriate Terminations – Part 1 (Posted July 2021)
• Ex Part Renewal: Strategies to Maximize Automation, Increase Renewal Rates, and Support Unwinding Efforts (Posted 10/20/2022)
• Preparing for the End of the COVID-19 Public Health Emergency: Opportunities to Support Medicaid and SNAP Unwinding Efforts (Posted 11/3/2022)
• Supporting Seamless Coverage Transitions for Children Moving Between Medicaid and CHIP in Separate CHIP States (Posted 12/12/2022)
• CIB: Medicaid and Children’s Health Insurance Program (CHIP) Renewal Requirements (Posted 12/4/2020)
• Opportunities to Support Unwinding Efforts for States with Integrated Eligibility Systems and/or Workforces (Posted 9/16/2022)
• Overview of Strategic Approach to Engaging Managed Care Plans to Maximize Continuity of Coverage as States Resume Normal Eligibility and Enrollment Operations (Posted 12/8/2021 and updated 3/15/2024)
• Eligibility & Enrollment Processing for Medicaid, CHIP, and BHP During COVID-19 Public Health Emergency Unwinding Key Requirements for Compliance (Posted 5/17/2022)
• Strategic Approaches to Support State Fair Hearings as States Resume Normal Eligibility and Enrollment Operations After the COVID-19 PHE (Posted 4/4/2022)

Best Practices & Strategies to Support Specific Populations

• Slide Deck: Ensuring Continuity of Coverage for Individuals Receiving Home and Community-Based Services (Posted 8/19/2024)
• Presentation: Strategies to Keep Children and Families Covered During Unwinding (Posted 8/11/2023)
• Medicaid and Children's Health Insurance Program (CHIP) Disability and Language Access Requirements Slide Deck (Posted 2/21/2023)
• Presentation: Strengthening Tribal and State Partnerships to Prepare for Unwinding (Posted 8/30/2022)
• Medicaid and CHIP Unwinding Planning Efforts: Summary of Best & Promising State Practices from CMS/State Discussions (Posted 4/4/2022)
• Connecting Kids to Coverage: State Outreach, Enrollment and Retention Strategies issue brief (Posted 11/24/2021)

Planning Tools & Templates

• Evidence to Document Compliance with Medicaid/CHIP Renewal Requirements (Posted 11/15/2024)
• Compliance Template: Assessment and Plan for Compliance with All Federal Medicaid and CHIP Renewal Requirements (Posted 9/20/2024)
• Scheduled State Timelines for Completing Unwinding-Related Renewals: Preliminary Analysis as of May 2024 (Posted 5/31/2024)
• Anticipated 2023 State Timelines for Initiating Unwinding-Related Renewals (Posted 6/30/2023)
• 60 Day Notice Timeline for States
• Letter to Governors on Unwinding (Posted 5/10/2022)
• General Transition Planning Tool for Restoring Regular Medicaid and Children’s Health Insurance Program Operations after Conclusion of the Coronavirus Disease 2019 Public Health Emergency (Posted 1/15/2021)
• Medicaid and Children’s Health Insurance Program COVID-19 Health Emergency Eligibility and Enrollment Pending Actions Resolution Planning Tool (Posted 1/15/2021 and updated 3/3/2022)
• Strategies States and U.S. Territories Can Adopt to Maintain Coverage of Eligible Individuals as they Return to Normal Operations (Posted 11/24/2021)
• Top 10 Fundamental Actions to Prepare for Unwinding and Resources to Support State Efforts (Posted 06/02/2022)
• Program Integrity Considerations for Restoring State Medicaid and Children’s Health Insurance Program Operations Upon Conclusion of the COVID-19 Public Health Emergency
  • Risk Assessment Template - Word Version
  • Risk Assessment Template - Excel Version
  • Risk Assessment Tool Webinar

Systems Resources

• Systems Readiness Artifacts Refresher (Posted 1/6/2023)
• Improving Efficiency and Beneficiary/Staff Experience Through Improved Renewal Automation For Unwinding (Posted 12/02/2022)
• Resources to Support System and Logic Testing for Unwinding (Posted 09/30/2022)

Outreach and Educational Resources

• Medicaid and CHIP Renewals Outreach and Educational Resources 

Medicaid/Marketplace Coordination Resources

• Extension of Temporary Special Enrollment Period (SEP) for Consumers Losing Medicaid or Children’s Health Insurance Program (CHIP) Coverage – Addendum to Frequently Asked Questions (FAQ) (Posted 3/28/2024)
• State Based Exchange (SBE) Priority Metrics: Medicaid/Children’s Health Insurance Program (CHIP) Continuous Enrollment Condition Unwinding Overview and Template (Posted 5/26/2023)
• Medicaid Continuous Enrollment Condition Unwinding Marketplace Frequently Asked Questions (FAQ) Companion Resource (Posted 5/26/2023)
• Medicaid Continuous Enrollment Condition Unwinding Marketplace Frequently Asked Questions (FAQ) (Posted 5/18/2023)
• Overview of Federal Marketplace Assister Outreach and Consumer Engagement Strategies (05/18/2023)
• New Federal Marketplace Reminder Letter Templates – See “Loss of Medicaid/CHIP Reminder Letters” in English or Spanish (05/18/2023)
• Temporary Special Enrollment Period (SEP) for Consumers Losing Medicaid or the Children’s Health Insurance Program (CHIP) Coverage Due to Unwinding of the Medicaid Continuous Enrollment Condition – Frequently Asked Questions (FAQ) (Posted 01/31/2023)
• FFM Inbound Account Transfer Matching Functionality Slide Deck (Posted 10/25/2022)
• Strategies for SBMs to Improve Medicaid to Marketplace Coordination and Maximize Enrollee Transitions at the End of the Continuous Enrollment Requirement
• Addressing Medicaid and CHIP Procedural Terminations in States that Operate a State-Based Marketplace with Account Transfers (PDF, 448.22 KB) (Posted 6/30/2022)
• CIB: Coordination of Eligibility and Enrollment between Medicaid, CHIP and the Federally Facilitated Marketplace (FFM or “Marketplace”) (Posted 7/25/2016)

State Technical Resource Guide for FFM Assessment & Determination States

• Overview: State Medicaid/CHIP Agencies Accepting Federally-facilitated Marketplace Eligibility Decisions
• Operational Implementation: State Medicaid/CHIP
• Additional Resources:
  • Outbound Account Transfer (AT): Identifying Eligibility Referral Reason and Verification Status
    • Supplemental Materials - OB AT – Identifying Elig. Referral Reason & Verification Status (Zip file)
  • Outbound Account Transfer Scenarios for States, Overview
  • Outbound Account Transfer Scenarios for States, Sample Payloads (Zip file)

CMCS Medicaid and CHIP All State Calls

In March of 2020, CMCS launched a regular All State Call series to bring the latest information available to support states and territories as they respond to the COVID-19 public health emergency and prepare for unwinding of COVID-19 flexibilities.

• Slide decks, transcripts, and recordings from CMCS’ Medicaid and CHIP All State Calls

Other Materials and Resources

Unwinding Documents