Renewals During Unwinding
• When the PHE ends, a state must initiate renewals for the state’s entire Medicaid, CHIP, and BHP population (total
caseload) within 12 months of the beginning of the state’s unwinding period and complete renewals within 14 months
of the beginning of the state’s unwinding period.
States may choose the month in which they begin initiating renewals that result in terminations, and begin their
unwinding period, in the month before, during, or after the PHE’s end date.
• States must initiate and complete renewals consistent with federal Medicaid, CHIP and BHP renewal requirements
for the total caseload during the unwinding period, including for:
• Enrollees for which the state already conducted a renewal during the PHE and found ineligible but did not
terminate, and
• Enrollees who were receiving benefits pending the outcome of a fair hearing on or after March 18, 2020 and
were continuously enrolled during the PHE
• In distributing renewals during the unwinding period, states should consider the impact of their choices on their
monthly renewal and fair hearing volume, both during the unwinding period and in future years, taking into account
their systems and workforce capacity
States will not have authority to allow states to redistribute renewals in future years (either by extending or
shortening renewal periods) after the 12-month unwinding period.
CMS State Health Official Letter # 22-001 RE: 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
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