Congress Sets April 1 as Medicaid Unwinding Start Date 2023

Unwinding Webinar #11: Congress Sets April 1 as Unwinding Start Date January 5, 2023

New Framework For End of Continuous Coverage Continuous Coverage De-Linked from PHE Enhanced FMAP Phases Down States that comply with applicable MOE requirements will receive: Enhanced FMAP for 2023 (in percentage points) Beginning April 1, 2023, states may begin disenrolling Medicaid enrollees who are no longer eligible after conducting a fresh and complete renewal Current MOE requirements continue to apply through March New MOE requirements starting April 1, 2023 6.2 5.0 2.5 1.5 Jan - Mar 2023 Apr - Jun 2023 Jul - Sept 2023 Oct - Dec 2023 2

Current Guidance and Expectations for States States have 12 months to initiate renewals; 14 months to complete Must complete fresh renewal for all enrollees CMS encourages states to initiate renewals for no more than 1/9 of caseload each month Guidance on coordinating with MCOs 1902(e)(14) waivers SNAP strategy No hit in income source No hit in AVS Accept updated addresses without notice to old address Extend timeframe on fair hearing requests 3

MOE Requirements Starting April 1, 2023 1. Conduct redeterminations in accordance with Federal requirements 2. Maintenance of up-to-date contact information Use NCOA, state human service agency, OR other reliable sources Attempt to ensure it has up-to-date contact information for enrollees (including mailing address, phone number and email address) 3. Attempt to contact beneficiaries prior to disenrollment Before disenrolling anyone based on returned mail Undertake good faith effort to contact individual using more than one modality Failure to comply = loss of enhanced FMAP for the quarter 4

March 31, 2023 = End of the Medicaid Continuous Coverage Provision Terminations may begin April 1, 2023 Jan 24 Apr 24 May 23 Jun 23 Sept 23 Mar 24 May 24 Mar 23 Apr 23 Dec 23 Jul 23 Feb 23 Feb 24 Aug 23 Oct 23 Nov 23 Option A: States begin 12-month unwinding period two months prior to first terminations on April 1, 2023 11 12 1 2 3 7 8 6 9 10 14 4 5 13 Option B: States begin 12-month unwinding period one month prior to first terminations on April 1, 2023 States may initiate renewals starting in February, March, or April 2023 11 12 1 2 3 7 8 6 9 10 14 4 5 13 Option C: States begin 12-month unwinding period the first month terminations are allowed April 1, 2023 11 12 1 2 3 7 8 6 9 10 14 4 5 13 Initiate Renewals Only Month 14: Last month to complete all unwinding- related E&E actions Month 12: Last month to initiate unwinding-related renewals Month 1: Begin initiating unwinding- related renewals Initiate Renewals & Process 5 Process Renewals Only

Unwinding Timeline Continuous coverage requirement ends 2023 2024 February March April May June July August September October November December January February March April May Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate Feb (60 day) Initiate Process Process Initiate Feb (75/90 day) Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate Initiate Process Process Process Initiate March (60 day) Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate Process Process Initiate March (75/90 day) Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate Initiate Process Process Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate April (60 day) Initiate Process Process Initiate April (75/90 day) Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate & Process Initiate Initiate Process Process Process First month of Medicaid terminations 6

Significant Transparency and Accountability Provisions Requires timely reporting of specific Medicaid related data that states should already reporting or getting ready to collect and report Applies to CHIP Adds Marketplace data reporting Directs CMS to publicly report the data Boosts accountability Following federal redetermination requirements and reporting data is required even if states choose to forgo the enhanced FMAP Financial penalties for noncompliance Additional enforcement authority for CMS 7

Specific Data Reporting Requirements Medicaid Data Marketplace Data* Renewals initiated Total # people renewed # renewed via ex parte (administrative renewals) # total disenrollments # of procedural disenrollments Call center volume, wait times, abandonment rate Other data specified by HHS Accounts transfers received from Medicaid** # of people determined eligible for a QHP or BHP (BHP only applies to NY and MN) # of people who selected plans or enroll in BHP * CMS may report on behalf of states using the FFM. **Does not apply to SBM states with integrated Medicaid/Marketplace eligibility system 8

Other Supplemental Data Required by CMS # of pending and completed applications Disaggregated by MAGI/other and disability-related coverage # of incomplete renewals # of outstanding renewals to be completed # of overdue fair hearings # people renewed using pre- populated form Additional Performance Indicator Data Enrollment Disaggregated by age or eligibility group; MAGI or non-MAGI Application processing times MAGI and non-MAGI reported separately based on different time frames Performance Indicator Data Dictionary Unwinding Data Specifications 9

State Financial Penalties for Not Reporting Data .25% reduction in FMAP for each quarter the state fails to report July 1, 2023 June 30, 2024 Applies to state FMAP for all medical expenditures Compounds for each quarter in which data is not reported Qtr 1 Qtr2 Qtr 3 Qtr 4 July Sept 2023 Oct Dec 2023 Jan - Mar 2024 Apr June 2024 State first reports in Qtr 3 .25% .50% -- -- State reports only in Qtr 2 & 3 .25% -- -- .50% State only reports Qtr 2 .25% -- .50% .75% State reports NO data .25% .50% .75% 1.00% Applies to all states, even if they chose to forgo the enhanced FMAP 10

Additional CMS Authority and Compliance Tools States must comply with all federal eligibility redeterminations requirements and unwinding data reporting requirements CMS may require a corrective action plan if a state is out of compliance Failure to submit or implement CAP CMS suspend some/all procedural disenrollments until state takes corrective action Impose civil monetary penalty of not more than $100,000 for each day a state is not in compliance, in addition to FMAP reduction Applies even if state forgoes enhanced FMAP Corrective Action Plan Timeline Submission Approval Implementation Notice 14 DAYS 14 DAYS 21 DAYS 11