State Compliance with Medicaid and CHIP Renewal Requirements: A Guide for MCOs

The Centers for Medicare & Medicaid Services (CMS) has updated Medicaid and CHIP renewal requirements, outlining deadlines and expectations for MCOs to ensure uninterrupted coverage for beneficiaries. Key dates, compliance steps, and documentation required by states are outlined below.

Key Deadlines and Requirements

By December 31, 2024, all states must submit their compliance assessments and renewal plans to CMS. Full compliance is required by December 31, 2026. MCOs must align their operations with these updates, impacting renewal processes and eligibility for Medicaid and CHIP beneficiaries.

Compliance Template

CMS has provided a template for states to report compliance with renewal requirements, including:

  • Compliance Assessment: States must confirm their compliance and provide supporting evidence.

  • Plan for Non-Compliance: States must outline corrective actions if non-compliant.

  • Evidence of Compliance: States must submit process flows, system documentation, and sample renewal packages.

MCO Key Responsibilities

MCOs must support state compliance efforts, including:

  1. Ex Parte Renewals: Ensure proper processing of renewals for MAGI and non-MAGI populations.

  2. Renewal Form Requirements: MCOs may need to provide communications and sample forms in line with CMS guidelines.

  3. Renewal Form Return Timeframes: MCOs should confirm states adhere to the 30-day return period for MAGI populations and "reasonable periods" for non-MAGI.

  4. Submission Modalities: Support systems that enable multiple submission methods (online, phone, paper, in-person).

  5. Reconsideration Period: Assist states with processing requests within the required 90-day period for MAGI beneficiaries.

  6. Eligibility Determinations: Ensure states are screening for all eligibility bases and transitions between Medicaid and the Marketplace.

What MCOs Need to Do

  • Review State Plans: Stay informed on state compliance assessments and identify areas where MCOs can support.

  • Align Systems: Adapt systems to meet state requirements for renewals and evidence submission.

  • Monitor Progress: Assist states with tracking compliance and documentation.

Conclusion

MCOs play a crucial role in supporting states to meet renewal compliance deadlines. By December 31, 2024, states must submit their plans to CMS. Full compliance must be met by December 31, 2026. Staying informed and proactive will help ensure uninterrupted coverage for Medicaid and CHIP beneficiaries. Agilian is here to help ensure that MCOs meet all renewal compliance deadlines!

For more details, visit the CMS website.

Previous
Previous

Proposed Expansion of Anti-Obesity Medication Coverage for Medicaid Beneficiaries: Implications for MCOs

Next
Next

Part 1: The Hidden Risks MCOs Face with Medicaid Disenrollments