Implementation of New Federal Rules and Policies in Medicaid

This timeline specifies the effective dates for many of the new policies and Medicaid improvements codified through recent federal changes.

June 3, 2024 (E&E rule – Part 2)

New option to allow medically needy individuals to deduct prospective medical expenses
Requirements to improve transitions between Medicaid and CHIP

October 1, 2024 (E&E rule – Part 1)

Requirement to automatically enroll SSI recipients in MSP

December 31, 2024 (Compliance)

Compliance plans for conforming to renewal requirements due to CMS

June 3, 2025 (E&E rule – Part 2)

Removal of requirement for Medicaid applicants to apply for other benefits
Premium lock-out periods no longer allowed
CHIP waiting periods no longer allowed
Annual and lifetime limits on CHIP benefits no longer allowed

July 9, 2025 (Access rule)

Requirement to establish MAC and BAC

December 3, 2025 (E&E rule – Part 2)

Requirement to check data sources and conduct outreach on returned mail

April 1, 2026 (E&E rule – Part 1)

Requirement for MSP family size definition to include at least the members in the LIS definition
Requirement to use LIS data as MSP application
Requirement to accept self-attestation for certain types of income and resources

June 3, 2026 (E&E rule – Part 2)

Requirement to modernize and improve recordkeeping practices
Expansion of acceptable data sources for citizenship verification

July 9, 2026 (Access rule)

States must publish their first annual report from MACs and BACs

December 31, 2026 (Compliance)

Deadline for states to be in compliance with renewal requirements

June 3, 2027 (E&E rule – Part 2)

Requirement to align non-MAGI renewal requirements with MAGI policies
Requirements for acting on changes in circumstances
Requirements for timely actions at determinations and redeterminations of eligibility

For more information, see the following:

Overview: Farah Erzouki, “Lessons From Unwinding Offer Opportunities to Streamline Medicaid, Improve Efficiency,” CBPP, April 3, 2025, https://www.cbpp.org/research/health/lessons-from-unwinding-offer-opportunities-to-streamline-medicaid-improve
Medicaid eligibility and enrollment rule — Part 1: Farah Erzouki, “Federal Rule on Medicare Savings Programs Will Cut Red Tape for Older Adults and People With Disabilities,” CBPP, May 3, 2024, https://www.cbpp.org/research/health/federal-rule-on-medicare-savings-programs-will-cut-red-tape-for-older-adults-and.
Medicaid eligibility and enrollment rule — Part 2: Tricia Brooks and Allexa Gardner, “Medicaid Eligibility and Enrollment Rule Explainer,” Georgetown Center for Children and Families, April 2024, https://ccf.georgetown.edu/wp-content/uploads/2024/05/Medicaid-EE-Rules-v2-rev.pdf.
Access rule: Laura Harker and Kaylin Hewitt, “Federal Changes Provide New Opportunities to Elevate the Voices of People With Lived Medicaid Experience in Policy Decisions,” CBPP, September 20, 2024, https://www.cbpp.org/research/health/federal-changes-provide-new-opportunities-to-elevate-the-voices-of-people-with.
Compliance with federal renewal requirements: Daniel Tsai, “CMCS Informational Bulletin: State Compliance with Medicaid and CHIP Renewal Requirements by December 31, 2026,” Centers for Medicare & Medicaid Services, September 20, 2024, https://www.medicaid.gov/federal-policy-guidance/downloads/cib09202024.pdf

Implementation of New Federal Rules and Policies in Medicaid

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Lessons From Unwinding Offer Opportunities to Streamline Medicaid, Improve Efficiency

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