Sneak Preview: States Set To Review Medicaid, CHIP Eligibility
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) State Medicaid agencies soon will receive a list from the Centers for Medicare and Medicaid Services (CMS) of individuals who may be enrolled in Medicaid or the Children’s Health Insurance Program (CHIP) in more than one state, and CMS recently issued an informational bulletin explaining actions that states should take when evaluating the eligibility of beneficiaries included on this list.
With rare exceptions, individuals are eligible for Medicaid and CHIP only in the state in which they reside, and states must promptly redetermine eligibility whenever a state receives information about a change in a beneficiary’s circumstances that may impact their eligibility, including a change to their state of residence. CMS estimates that about 1.2 million individuals each month may be enrolled in Medicaid or CHIP in more than one state, adding that providing benefits to multiple-state enrollees cost these programs millions of state and federal dollars.
The agency “aims to ensure, as expeditiously as possible and within the bounds of the law, that individuals who are otherwise Medicaid- or CHIP-eligible are enrolled only in the Medicaid program or CHIP of their state of residence, not in multiple states’ programs,” the bulletin noted, adding that CMS “is also committed to ensuring that Medicaid- and CHIP-eligible individuals are not improperly enrolled concurrently in Medicaid or CHIP and in subsidized health insurance exchange coverage.”
CMS plans to send each state a “concurrent enrollment file” on Medicaid and CHIP beneficiaries who potentially may be also enrolled in another state, and directed states to promptly evaluate the eligibility of these beneficiaries and take action to terminate coverage if the state determines a beneficiary is no longer eligible based on residency.
CMS also provided state-based health insurance exchanges with information on individuals who are potentially enrolled in the state’s Medicaid program or CHIP and an exchange plan to help the exchanges determine whether these individuals are concurrently enrolled, and if so, direct them to implement a process to redetermine eligibility as required under regulation.
(The full version of this story has now been made available to all for a limited time here.)
Join us for our following Thompson Grants event:
2025 Thompson Grants Workshop: Subrecipient Monitoring | Dec. 9, 2025 | Virtual Event