Page 5

Page 5 – CMCS Informational Bulletin retain Medicaid, CHIP, and Basic Health Program (BHP) coverage.5 The Eligibility and Enrollment final rule went into effect on June 3, 2024, and CMS outlined a phased-in approach for states to come into compliance with each provision between 2024 and 2027. Section 71102 temporarily prohibits CMS from implementing, administering, or enforcing certain amendments made by the provisions of the Eligibility and Enrollment final rule that had a compliance date after July 4, 2025, the date the WFTC legislation was enacted. The moratorium on these amendments ends on September 30, 2034. While the moratorium is in effect, CMS will, in general, revert to the regulations in place as of June 2, 2024, for sections of the regulation subject to the moratorium.6 CMS continues to analyze the impact of the moratorium on eligibility and enrollment processes and expects to provide additional information to states in future guidance. See Appendix F for the complete list of provisions in the Eligibility and Enrollment final rule and their status under the moratorium. Section 71102 affects regulations applicable to all states, the District of Columbia, and the territories. Section 71103. Reducing Duplicate Enrollment under the Medicaid and CHIP Programs Section 71103 creates two new state plan requirements related to address verification for states at new paragraph (88) under section 1902(a) of the Social Security Act (the Act) for Medicaid, with corresponding amendments to section 2107(e)(1) of the Act to apply these requirements to separate CHIPs. Beginning no later than January 1, 2027, each of the 50 states and the District of Columbia will need to have a process to regularly obtain address information from the following “reliable data sources”: mail returned by the U.S. Postal Service with a forwarding address; the U.S. Postal Service National Change of Address Database; certain managed care entities (i.e., managed care organizations (MCOs); prepaid inpatient health plans (PIHPs); prepaid ambulatory health plans (PAHPs); primary care case manager (PCCM)); and other data sources as identified by the state and approved by the Secretary. Based on this information, states must take such actions as the Secretary specifies with respect to any address changes for individuals enrolled under the state plan (or a waiver of such plan). Beginning January 1, 2027, this provision also requires that each contract under a state plan that a state has with certain entities or plans (MCOs, PIHPs, PAHPs and PCCMs) require that such entity or plan promptly transmit to the state any address information received directly from enrollees or verified by the entity or plan directly with the enrollee. This provision builds on processes many states established during the COVID-19 Public Health Emergency (PHE), since 5 https://www.federalregister.gov/documents/2024/04/02/2024-06566/medicaid-program-streamlining-the-medicaid- childrens-health-insurance-program-and-basic-health 6 https://www.ecfr.gov/on/2024-06-02/title-42/chapter-IV/subchapter-C