On August 31, 2022, CMS announced a proposed rule for Streamlining Eligibility and Enrollment. CMS notes that the provisions set forth in this rule are intended to provide greater ease for applicants seeking Medicaid, CHIP and Basic Health Plan coverage by reducing administrative burden through a simpler application, verification, enrollment, and renewal process. CMS purports that the changes proposed would remove barriers to enrollment and increase the number of eligible individuals who obtain coverage and are continuously enrolled in Medicaid and CHIP. The proposed rule would ease the application and verification processes by aligning requirements across Medicaid and CHIP; simplifying transitions between programs; providing timeliness standards across renewals and redeterminations of eligibility; promoting greater access by eliminating premium lock-out periods, waiting periods, and benefit limitations; and leveraging modern technologies to standardize recordkeeping.

The provisions within the proposed rule will require careful evaluation by states due to the volume of the changes and the impact the proposals may have on state policies, processes, information systems, and administrative capacities. CMS has requested feedback from stakeholders on implementation timeframes as well as the rationale for the recommended timeframes and views related to the impact that the changes may have on state efforts to resume eligibility and enrollment policies, processes, and procedures during the public health emergency unwinding period.  Some states may also require changes in state laws and regulation to meet the provisions within the proposed rule, which could have a substantial impact on the ability to quickly make proposed changes. There is 60-day comment period for stakeholders, with comments due on November 7, 2022.

The impending rule includes substantial changes and adjustments in six specific areas to restructure eligibility and enrollment within Medicaid and CHIP, including:

  • Facilitating Medicaid Enrollment
  • Promoting Enrollment and Retention of Eligible Individuals
  • Eliminating Barriers to Access in Medicaid
  • Recordkeeping
  • Streamlining Enrollment and Promoting Retention and Beneficiary Protections in CHIP
  • Eliminating Access Barriers in CHIP

The Research & Policy Team at Sellers Dorsey summarized the proposed regulations which we identified as having a specific impact on health care and human services providers, payers, and other stakeholders. Download the full summary here.