HomeHealth LawContinuity in Protection: CMS Extends the Unwinding SEP & Points Remaining Rule...

Continuity in Protection: CMS Extends the Unwinding SEP & Points Remaining Rule for Medicaid and CHIP Enrollment

On March 28, 2024, the U.S. Division of Well being and Human Providers (HHS), by the Facilities for Medicare & Medicaid Providers (CMS), introduced that it’s extending the non permanent particular enrollment interval (the Unwinding SEP) for prior beneficiaries of Medicaid and Medicaid-expansion Kids’s Well being Insurance coverage Packages (CHIP) to enroll within the Well being Insurance coverage Market (Market). The Unwinding SEP was beforehand scheduled to terminate on July 31, 2024, however now the top date is prolonged to November 30, 2024. This 4-month extension will assist tens of millions preserve insurance coverage protection as they navigate their new post-pandemic eligibility statuses.

Moreover, on April 2, 2024, CMS launched Half 2 of a complementary Remaining Rule on Streamlining the Medicaid, CHIP, and Primary Well being Program Utility, Eligibility Dedication, Enrollment, and Renewal Processes. Whereas the Unwinding SEP extension helps guarantee protection continuity for these just lately ineligible for Medicaid and CHIP, the Remaining Rule does the identical for individuals who are nonetheless Medicaid or CHIP eligible. The Remaining Rule takes impact on June 3, 2024.

The COVID-19 Steady Enrollment Requirement

Earlier than the pandemic, state Medicaid companies carried out yearly eligibility critiques of Medicaid and CHIP enrollees and had been permitted to disenroll ineligible people. Throughout the COVID-19 pandemic, within the spring of 2020, Congress enacted the Households First Coronavirus Response Act (FFCRA), which paused this eligibility assessment course of and prohibited state Medicaid companies from involuntarily disenrolling beneficiaries or transferring enrollees to a special protection group that gives a extra restrictive profit bundle. Medicaid and Medicaid-expansion CHIP applications had been required to keep up steady enrollment for all beneficiaries by the length of the COVID-19 public well being emergency (PHE) in change for enhanced federal funding. This requirement protected protection for beneficiaries whose circumstances modified such that they had been now not historically eligible for Medicaid or CHIP.

Mass Disenrollment and the Unwinding SEP

The PHE ended within the spring of 2023, and the 2023 Consolidated Appropriations Act ended the Medicaid and CHIP steady enrollment requirement on March 31, 2023. The termination of this requirement successfully resumed the pre-pandemic established order, allowing states to abruptly disenroll Medicare and CHIP beneficiaries. This mass-disenrollment occasion “current[ed] the single largest well being protection transition occasion because the first open enrollment interval of the Inexpensive Care Act.” Roughly 15 million people (17.4% of all Medicaid and CHIP beneficiaries) grew to become in danger for lack of medical health insurance protection. Disenrollment from Medicaid and CHIP applications has been occurring since final March on a rolling foundation, catching off-guard beneficiaries who had been beforehand assured protection for years and leading to insurance coverage protection disruptions.

To mitigate these insurance coverage protection disruptions, in January of 2023, CMS created the Unwinding SEP, allowing just lately disenrolled Medicaid and CHIP beneficiaries to enroll in a Market plan exterior of the traditional open enrollment window. The Market is a government-run portal the place people who are usually not eligible for Medicaid or CHIP and who would not have employer-based insurance coverage can evaluate and enroll in reasonably priced insurance coverage insurance policies. The usual open enrollment interval for the Market is November 1 to December 15, so with out this Unwinding SEP, people who had been disenrolled from Medicaid and CHIP exterior of this window would have lacked the chance to keep up reasonably priced protection within the interval between their disenrollment and the usual Market open enrollment interval. The Unwinding SEP initially opened Market enrollment from March 31, 2023 by July 31, 2024.

2024 Unwinding SEP Extension

Now, the Unwinding SEP has been prolonged by November 30, 2024. This extension will assist these just lately excluded from Medicaid or CHIP to promptly safe reasonably priced, complete protection by the beginning of the subsequent open enrollment interval. People who’re just lately non-Medicaid/CHIP-eligible however are Market-eligible can apply for insurance coverage anytime through the prolonged Unwinding SEP at HealthCare.gov.

Complementary Remaining Rule: Streamlining Medicaid and CHIP Enrollment and Renewal

Hand-in-hand with the Unwinding SEP extension, which is geared toward safeguarding protection for these just lately ineligible for Medicaid or CHIP, is the Remaining Rule, which establishes a number of measures to safeguard protection for these nonetheless eligible for Medicaid or CHIP. The Remaining Rule endeavors to lower the executive obstacles to Medicaid and CHIP enrollment and renewal, particularly by:

  • Prohibiting states from requiring in-person interviews for these whose eligibility relies on having a incapacity or being a minimum of 65 years outdated;
  • Permitting flexibility for beneficiaries with a incapacity or who’re 65+ to resume protection through cellphone, mail, in-person, or on-line;
  • Eradicating the choice for states to impose a “Lock-Out Interval,” which quickly blocked households from re-enrolling after a missed CHIP premium cost;
  • Requiring Medicaid companies to examine sure classes of obtainable information previous to terminating enrollment when beneficiaries can’t be reached through mail; and
  • Requiring Medicaid companies to offer potential beneficiaries a minimum of 15 calendar days to return supplemental info requests in reference to an software, and 30 calendar days to return info in reference to a renewal.


Each CMS’s extension of the Unwinding SEP and publication of the Remaining Rule increase upon its efforts over the previous yr to guard insurance coverage protection for tens of millions through the post-PHE transition interval. For extra details about the Remaining Rule’s changes to the Medicaid and CHIP enrollment and retention processes, see the Remaining Rule Reality Sheet.

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