Colorado Response to the Availability of Unwinding-Related Section 1902(e)(14)(A) Waivers Beyond June 30, 2025
This is a preliminary analysis of the waiver continuation options by HCPF staff. Colorado will be working with stakeholders to gather their perspectives.
| # | 1902(e)(14)(A) Strategy | Original Strategy Description | Continued Availability of Strategy | Rationale and Authority for Continued Availability or Discontinuation of Strategy | Colorado Comments |
|---|---|---|---|---|---|
| 1 | Applying for Other Benefits Strategy | Suspend the requirement to apply for other benefits under 42 C.F.R. § 435.608. | Strategy required by the April 2024 Eligibility and Enrollment Final Rule. | Under the April 2024 Eligibility and Enrollment Final Rule, the requirement to apply for other benefits as a condition of Medicaid eligibility (42 C.F.R. § 435.608) has been eliminated for all applicants and beneficiaries, effective June 3, 2024. All states must eliminate any requirement to apply for other benefits as a condition of Medicaid eligibility by no later than June 3, 2025, and may do so sooner. | Colorado did not select this e(14) waiver during Unwind. No action is necessary as Colorado does not have the requirement that members apply for other benefits when they apply for or renew Medicaid. |
| 2 | Supplemental Nutrition Assistance Program (SNAP)/Temporary Assistance for Needy Families (TANF) Strategy | Enroll and/or renew Medicaid eligibility for Modified Adjusted Gross Income (MAGI) or non- MAGI-based individuals based on gross income findings from SNAP or TANF. | Optional strategy under state plan to use SNAP gross income for MAGI populations. | Section 1137 of the Act and implementing regulations at 42 C.F.R. § 435.948 identify SNAP as one of the data sources states are required to access to the extent the state determines SNAP to be useful for verifying income. In determining usefulness, CMS expects states to consider such factors as the accuracy of the financial information, the timeliness of the information returned, the complexity of accessing the data or data source, the age of the financial records, the comprehensiveness of the data, any limitations imposed by the owner of the data on its use, as well as other relevant factors. Consistent with the aforementioned factors for consideration, CMS expects states to exercise reasonable judgement in determining what data from the data source is useful for verifying income. To implement this strategy at application, renewal, or both, states must document their use of SNAP gross income in their verification policies and procedures. At this time, CMS is not requiring states to submit updated verification plans with any new policies based on the flexibilities described in this guidance.** CMS may require specific policies detailed in this guidance be included in verification plans in the future. CMS approval of state verification plans is not required, but states must submit their plans to CMS upon request, consistent with 42 C.F.R. § 435.945(j). *Note: If a state is interested in using the gross income determination from a human service program other than SNAP, such as TANF, or is interested in using SNAP gross income for non-MAGI populations, the state must conduct and share with CMS an analysis to determine whether that program’s gross income determination would be a useful data source for verifying income. **CMS is requiring states to submit their updated MAGI-based verification plans to CMS if a state implementing this policy does not already include SNAP as a useful data source for verifying financial information. | Colorado selected this e(14) waiver during Unwind and will continue to use SNAP gross income to determine MAGI Medicaid eligibility. There will be system changes to remove the option of use TANF gross income which was authorized under the original e(14) waiver, but is not longer an option beyond June 30, 2025. Colorado is authorized to continue this waiver through Authorized HB 24-1400. |
| 3 | $0 Income Strategy | Renew Medicaid eligibility for individuals with no income and no data returned on an ex parte basis. | Optional strategy under state plan. | For individuals with a previously-verified attestation of zero-dollar income, if the state has checked all available income data sources in accordance with its verification plan and no information is received, the state may consider the previously-verified income determination in the beneficiary’s account as reliable under 42 C.F.R. § 435.916(b)(1) in conducting an ex parte renewal without requesting additional information or documentation of income. To implement this strategy, a state would need to comply with regulatory requirements and guardrails detailed in this CIB. States that adopt this strategy on a permanent basis must establish the maximum amount of time that has elapsed since the state last verified zero-dollar income without using this strategy (either at initial application or a renewal). To implement this strategy, states must document its use in their verification policies and procedures. At this time, CMS is not requiring states to submit updated verification plans with any new policies based on the flexibilities described in this guidance. CMS may require specific policies detailed in this guidance be included in verification plans in the future. CMS approval of state verification plans is not required, but states must submit their plans to CMS upon request, consistent with 42 C.F.R. § 435.945(j). | Colorado selected this e(14) waiver during Unwind and will continue to use this strategy for individuals when no data is returned from electronic interfaces during the renewal process. There will be required system changes to comply with CMS direction to established a three year timeframe to reverify the member's income submitted and verified on the original application. Colorado is authorized to continue this waiver through Authorized HB 24-1400. |
| 4 | 100 Percent Income Strategy | Renew Medicaid eligibility for individuals with income at or below 100 percent of the federal poverty level (FPL) and no data returned on an ex parte basis. | Optional strategy under state plan. | For individuals with previously-verified income at or below 100 percent of the FPL, if the state has checked all available income data sources in accordance with its verification plan and no information is received, the state may consider the previously-verified income determination in the beneficiary’s account as reliable under 42 C.F.R. § 435.916(a) in conducting an ex parte renewal without requesting additional information or documentation of income. To implement this strategy, a state would need to comply with regulatory requirements and guardrails detailed in this CIB. States that adopt this strategy on a permanent basis must establish the maximum amount of time that has elapsed since the state last verified income at or below 100 percent of FPL without using this strategy (either at initial application or a renewal). States may choose a lower FPL at which to implement the 100 percent FPL strategy. To implement this strategy, states must document its use in their verification policies and procedures. At this time, CMS is not requiring states to submit updated verification plans with any new policies based on the flexibilities described in this guidance. CMS may require specific policies detailed in this guidance be included in verification plans in the future. CMS approval of state verification plans is not required, but states must submit their plans to CMS upon request, consistent with 42 C.F.R. § 435.945(j). | Colorado selected this e(14) waiver during Unwind and will continue to use this strategy for individuals when no data is returned from electronic interfaces during the renewal process. There will be required system changes to comply with CMS direction to established a three year timeframe to reverify the member's income submitted and verified on the original application. Colorado is authorized to continue this waiver through Authorized HB 24-1400. |
| 5 | Streamlining Asset Determinations Strategy | Renew Medicaid eligibility without regard to the resource test for non-MAGI beneficiaries who are subject to a resource test. | Optional strategy under state plan. | Pursuant to the longstanding authority in section 1902(r)(2) of the Act, states may disregard (i.e., not count) otherwise countable income and/or resources in making non-MAGI eligibility determinations. For example, a number of states disregard all assets for the Medicare Savings Program groups described in Section 1902(a)(10)(E)(i), (iii), and (iv) of the Act. Similarly, states may disregard increases in assets beneficiaries experience after their date of application. To implement this strategy, a state would need to submit an eligibility state plan amendment to apply a 1902(r)(2) disregard and specify the non-MAGI eligibility groups to which the disregard would apply. | Colorado did not select this e(14) during Unwind and we are not authorized to disregard assets through the application or renewal process. This option does not authorize the ability to skip the verification of assets, but rather eliminates the counting certain assets. To implement this option, a statute change and corresponding budget action would be necessary. |
| 6 | Asset Verification System (AVS) Strategy | Renew Medicaid for individuals for whom information from the AVS is not returned or is not returned within a reasonable timeframe. | Optional strategy under state plan. | Provided a state builds into its ex parte renewal process a reasonable period of time for financial institutions to respond to an AVS query, CMS has determined that the state may assume no change in the value of a previously-verified asset if the state submits a request through its AVS and no information is returned or there is no response from the AVS within the reasonable timeframe the state has established. Regulations at 42 C.F.R. § 435.916 afford states the flexibility to determine that certain assets are unlikely to appreciate in value and allow states to rely on the value of the asset in a beneficiary’s account at renewal. This strategy would enable the state to complete an ex parte renewal for some beneficiaries without requesting additional documentation for asset types that can be verified with AVS. Specifically, if an individual only has assets held in financial institutions, or their only other assets are not likely to appreciate in value, the state would be able to complete an ex parte renewal, without any further verification of assets. To implement this strategy, states should document its use in their verification policies and procedures. At this time, CMS is not requiring states to submit updated verification plans with any new policies based on the flexibilities described in this guidance CMS may require specific policies detailed in this guidance be included in verification plans in the future. CMS approval of state verification plans is not required, but states must submit their plans to CMS upon request, consistent with 42 C.F.R. § 435.945(j). | Colorado did not pursue this waiver since the state does not currently have an Asset Verification System that can perform real-time verifications during the renewal process. However, a system change is scheduled in December 2025 that will allow the real-time verification of assets during the renewal process. Colorado is authorized to implement this change through HB 24-1400. |
| 7 | Stable Income and Asset Strategy | Renew Medicaid eligibility for individuals with only Title II or other stable sources of income (e.g., pension income) or stable assets (e.g., burial funds) without checking required data sources. | Optional strategy under state plan. | States have flexibility to make a reasonable determination of what types of income and assets are highly likely to remain stable (or decrease in value) in conducting an ex parte renewal under 42 C.F.R. § 435.916(b)(1). Stable sources of income may include income from a fixed pension, as this generally does not change year to year. Fixed distributions of dividends or interest and non-retirement fixed annuities are also likely to remain stable. Assets that are highly unlikely to increase in value, and may even decrease, include the value of a second vehicle (if considered in determining countable assets), burial funds, special needs trusts (provided that the state clearly advises beneficiaries on their responsibility to report any changes to the terms of the trust), and some life insurance policies. Therefore, states may, when attempting an ex parte renewal per 42 C.F.R. § 435.916(b)(1), assume no change in those income sources or assets determined by the state to be stable without checking data sources. In these instances, states use the stable income or asset in the beneficiary case file as verified information when determining financial eligibility. To implement this strategy states should document its use in their verification policies and procedures. At this time, CMS is not requiring states to submit updated verification plans with any new policies based on the flexibilities described in this guidance. CMS may require specific policies detailed in this guidance be included in verification plans in the future. CMS approval of state verification plans is not required, but states must submit their plans to CMS upon request, consistent with 42 C.F.R. § 435.945(j). | Colorado did not select this e(14) during Unwind. A system change is scheduled in December 2025 that will allow the real-time verification of assets during the renewal process. Once that is system change is completed, Colorado can implement recommendations on which previously verified assets to not verify again through during the renewal process as authorized through statute and state regulations. |
| 8 | Medical Support Cooperation Strategy | Suspend the requirement to cooperate with the agency in establishing the identity of a child's parents and in obtaining medical support. | Blanket authority discontinued after June 30, 2025. | Under sections 1912 and 1902(a)(45) of the Act and 42 C.F.R. §§ 435.610, 433.145, 433.147, and 433.148, beneficiaries are required either to cooperate with the state in obtaining, from liable third parties, medical support and payments for themselves or for a person for whom the individual can legally assign rights, or to establish good cause for not doing so. Individuals who assign the rights to medical support and payments on behalf of a child must also cooperate with the state in establishing the identity of the child’s non-custodial parent(s) or establish good cause for not doing so. Individuals (unless exempt per regulations at 42 C.F.R. §§ 435.610, such as pregnant individuals) must agree to cooperate in establishing paternity and obtaining medical support at application. At application, individuals must indicate that they are willing to fulfill these cooperation requirements unless they are exempt, but states cannot require such individuals to take concrete steps to meet medical support cooperation requirements until after enrollment. CMS encourages states to evaluate their policies and practices to identify opportunities to streamline medical support cooperation enforcement and ensure eligible individuals enroll in and retain Medicaid coverage. For more information see CMS, “Medicaid Medical Support Requirements and Implementation Strategies,” June 2023.26 | Colorado did not select this e(14) during Unwind. The authority to continue this process is discontinued after June 30, 2025. |
| 9 | Managed Care Organization (MCO) Renewal Support Strategy | Permit MCOs to provide assistance to beneficiaries to complete and submit Medicaid renewal forms. | Optional strategy under state plan. | Existing managed care regulations do not prohibit MCOs from conducting outreach and assisting beneficiaries with completing and submitting renewal forms, provided that the plan does not provide choice counseling (defined at 42 C.F.R. § 438.2). MCOs may not complete any renewal form fields related to plan choice and may not sign the renewal form on behalf of the beneficiary. To implement this strategy, a state would need to document their choice to do so in their state policy manual and make the manual available to CMS upon request. | Colorado did not select this e(14) waiver during Unwind. There are no plans to expand RAEs and MCOs as eligibility sites. Instead Regional Accountable Entities (RAEs) and MCOs will continue to outreach to members during the renewal process. Adding RAEs and MCOs as eligibility sites would require system changes and operational resources that are not currently budgeted. |
| 10 | Telephonic Signature Recording Strategy | Waive the recording of the telephone signature at application and/or renewal from the applicant or beneficiary. | Blanket authority discontinued after June 30, 2025. | Per 42 C.F.R. §§ 435.907(f) and 435.916(b)(2)(ii)(B), all initial applications and renewal forms must be signed under penalty of perjury. Signatures transmitted telephonically must be recorded. When recording a telephonic signature, states have flexibility to record the entire application or renewal conversation, including the signature under penalty of perjury, or to record only the signature under penalty of perjury. | Colorado did not select this e(14) waiver during Unwind. Colorado will maintain an existing process that can be used by all eligibility workers statewide to obtain a telephonic signature from the applicant or beneficiary and record/store it appropriately. |
| 11 | Authorized Representative Designation Strategy | Permit the designation of an authorized representative for the purposes of signing an application or renewal form via the telephone without a signed designation from the applicant or beneficiary. | Blanket authority discontinued after June 30, 2025. | 42 C.F.R. § 435.923 requires that applicants and beneficiaries be able to designate an authorized representative to act on their behalf and that the signature of the applicant or beneficiary be included with the designation. Signatures must be accepted in all modalities available at 42 C.F.R. § 435.907(f), including by telephone. | Colorado did select this e(14) waiver during Unwind. The authority to continue this process is discontinued after June 30, 2025. Colorado will need to issue policy guidance to end the current process that ends on June 30, 2025. |
| 12 | National Change of Address (NCOA) and/or U.S. Postal Service (USPS) Contact Update Strategy | Update the beneficiary’s case record with the updated in-state contact information received from the NCOA database or USPS returned mail without first sending a notice to the beneficiary address on file with the state. | Strategy required by the April 2024 Eligibility and Enrollment Final Rule. | Under 42 C.F.R. §§ 435.919(f)(1) and 457.344, states must establish a process to obtain updated address information from reliable sources, including the NCOA, mail returned by USPS with a forwarding address, and MCOs. If the state receives an updated in-state address from a reliable source, it must accept the information, update the beneficiary's case record with the updated address, and notify the beneficiary of the change in accordance with 42 C.F.R. §§ 435.919(f)(2) and 457.344. States may not require verification of an address change from the beneficiary prior to updating their record. This requirement was finalized by the April 2024 Eligibility and Enrollment final rule. All states must comply with this requirement by December 3, 2025, and may implement it sooner. | Colorado did select this e(14) waiver during Unwind and will continue to use this strategy, The process is mostly operational now, but there will be system changes necessary to implement notification to members about an address change. In addition, further system changes are necessary to streamline the information from USPS/NCOA. |
| 13 | Managed Care Organization (MCO) Beneficiary Contact Update Strategy | Update the beneficiary’s case record with the updated in-state contact information received from an MCO without first sending a notice to the beneficiary address on file with the state. | Strategy required by the April 2024 Eligibility and Enrollment final rule. | See description above for NCOA and/or USPS Contact Update Strategy. | Colorado did not implement this e(14) waiver during Unwind, but will work with our RAEs and MCOs to create a process for them to provide updated member information to the existing return mail center which performs research and outreach to updated member contact information. |
| 14 | Enrollment Broker and/or Program of All-Inclusive Care for the Elderly (PACE) Contact Update Strategy | Update the beneficiary’s case record with the updated in-state contact information received from enrollment brokers and/or PACE organizations without first sending a notice to the beneficiary address on file with the state. | Optional strategy under April 2024 Eligibility and Enrollment final rule. | 42 C.F.R. §§ 435.919(f)(1)(iii)(D) and 457.344 provide states with flexibility to deem other sources identified by the agency and approved by the Secretary as reliable for purposes of obtaining updated contact information. States may opt to deem enrollment brokers and/or PACE organizations to be reliable sources. If this option is elected, the state must, upon receipt of an updated in-state address from an enrollment broker and/or PACE organization, accept the information, update the beneficiary’s case record with the updated address, and notify the beneficiary of the change in accordance with 42 C.F.R. §§ 435.919(f)(2) and 457.344. To implement this option, states should clearly document use of this strategy in internal files, for audit and other purposes. States may be asked to provide these documents to CMS upon request. | Colorado did not select this e(14) during Unwind. Colorado leveraged and will continue to leverage a centralized return mail center for this function. The centralized return mail center is seen as a best practice to update member contact information. |
| 15 | 12-Month Extension for Children and/or Non-MAGI Beneficiaries Strategy | Renew Medicaid eligibility for children and/or non-MAGI beneficiaries for 12 months based on the individual’s most recent Medicaid determination without conducting a renewal or making a new eligibility determination. | Blanket authority discontinued after June 30, 2025. | Regulations at 42 C.F.R. §§ 435.916 and 457.343 require states to conduct renewals and make a new eligibility determination for most individuals enrolled in Medicaid and CHIP once every 12 months. States currently must conduct MAGI-based renewals once every 12 months. The requirement for states to conduct non-MAGI based renewals once every 12 months (instead of at least once every 12 months) was finalized by the April 2024 Eligibility and Enrollment final rule. All states must comply with this requirement for non-MAGI based renewals by June 3, 2027, and may implement it sooner. | Colorado did not select this e(14) during Unwind. The authority to continue this process is discontinued after June 30, 2025. |
| 16 | Medicaid Premium Resumption Delay Strategy | Delay the resumption of Medicaid premiums otherwise approved under the state plan for a beneficiary until the individual’s redetermination is completed. | Blanket authority discontinued after June 30, 2025. | States may not generally suspend premiums for some individuals in a population subject to a premium and not others. States may request to eliminate premiums for all individuals in a given population(s) currently subject to a premium by submitting a state plan amendment. | Colorado did suspend premiums for Medicaid Buy-In programs for working disabled adults and disabled children through a State Plan option not through an e(14) waiver. The blanket authority discontinued after June 30, 2025. However, Colorado can still eliminate premiums through a State Plan option. Legislation and a corresponding budget action is necessary to authority this change. |
| 17 | Former Foster Care Children (FFCC) Strategy | Extend eligibility in the FFCC group to youth formerly in foster care from any state, without regard to when the individual turned age 18. | Blanket authority discontinued after June 30, 2025. | Under section 1002(a) of the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act (Pub. L. 115-271), states must apply different eligibility rules in determining eligibility for the FFCC group under section 1902(a)(10)(A)(i)(IX) of the Act based on when an individual reaches age 18. As discussed in State Health Official Letter #22-00327, states may request to establish a section 1115 demonstration to cover youth formerly in foster care from other states regardless of when an individual reaches age 18. | Colorado did not select this e(14) waiver during Unwind. The authority to continue this process is discontinued after June 30, 2025. |
| 18 | Fair Hearings Timeframe Extension Strategy | Extend the timeframe permitted for the state to take final administrative action on fair hearing requests, greater than the 90-day time limit, provided that state provides benefits pending the outcome of the fair hearing to all appellants. | Blanket authority discontinued after June 30, 2025. | States must take final administrative action on all fair hearing requests within 90 days from the date the individual filed the fair hearing request in accordance with 42 C.F.R. § 431.244(f)(1), unless the agency cannot reach a decision because the appellant requests a delay or fails to take a required action, or an administrative or other emergency beyond the agency’s control prevents it from doing so (42 C.F.R. § 431.244(f)(4)(i)(A) and (B)). | Colorado did select this e(14) waiver during Unwind. The authority to continue this process is discontinued after June 30, 2025. Colorado will no longer automatically extend benefits pending the outcome of the fair hearing for all members that appeal. In order for members to have their benefits continued during an appeal, members will now need to appeal before their current coverage end date expires rather than appealing anytime during the 60 day appeal period. |
| 19 | State Agency and/or Other Qualified Entities Using Presumptive Eligibility (PE) Strategy | Designate state agency, pharmacies, community- based organizations (CBOs), and/or other providers as qualified entities to make determinations of PE on a MAGI basis for individuals not enrolled in Medicaid or CHIP. | Optional strategy under state plan. | Under federal regulations at 42 C.F.R. §§ 435.1103 and 457.355, states may permit qualified entities, including the state agency itself, pharmacies, CBOs, and/or other providers, to make PE determinations on a MAGI-basis for individuals not enrolled in Medicaid or CHIP. Once determined eligible for PE, the PE period begins on the day that the qualified entity approves PE. If a full Medicaid/CHIP application is submitted by the last day of the month after the month that PE is determined, the PE period ends on the date full Medicaid eligibility is approved or denied. If a full Medicaid and/or CHIP application is not submitted by the last day of the month after the month that PE is determined, the PE period ends on that day. States may require qualified entities to assist individuals with a PE determination in completing a Medicaid/CHIP application. Consistent with requirements at 42 C.F.R. §§ 435.916(b)(2)(iii) and 457.343, this strategy allows state agencies to treat a renewal form returned during the reconsideration period for individuals with a PE determination as a Medicaid/CHIP application for the purposes of extending the PE period until the state determines eligibility. States electing this option would provide adequate training to qualified entities making PE determinations to assist individuals with completing a Medicaid application or renewal form for individuals whose coverage had been terminated for failure to timely submit the renewal form. If a state designates itself as a qualified entity to make PE determinations, the state agency would treat a Medicaid application or renewal as a PE application and use the information on the application or renewal form to make a PE determination. To implement this strategy, states would submit a PE state plan amendment to adopt PE (if not already adopted in the state plan), and elect the option to treat renewal forms returned during the reconsideration period as a Medicaid/CHIP application for purposes of extending the PE period. States electing this option must also allow full Medicaid applications to extend the PE period for individuals with a PE determination. The state would list the qualified entities it is designating to make PE determinations and the MAGI populations it is electing to cover through PE in accordance with 42 C.F.R. § 435.1103. | Colorado did not select this e(14) waiver during Unwind. Colorado will continue to explore expanding Presumptive Eligibility (PE) sites following our implementation of PE sites at hospitals in January 2026. Any expansion will require additional resources to perform training and oversight of applications from PE sites and then the timely completion of the entire application. |
| 20 | Reinstate Eligibility Back to Termination Date During Reconsideration Period Strategy | Reinstate eligibility effective on the individual’s prior termination date for individuals who were disenrolled based on a procedural reason and are subsequently redetermined eligible for Medicaid during a 90-day reconsideration period. | Blanket authority discontinued after June 30, 2025. | Medicaid and CHIP regulations do not otherwise support reinstatement of an individual’s eligibility back to the date of termination prior to a determination of eligibility based solely on the returned renewal form. However, consistent with 42 C.F.R. § 435.915, states must provide up to three months of retroactive eligibility for individuals disenrolled for procedural reasons who are subsequently determined eligible for Medicaid during the reconsideration period, if the individual received Medicaid services in the three months prior to returning the renewal form and met Medicaid eligibility requirements when services were received. This enables a state to close or minimize potential coverage gaps. | Colorado did select this e(14) waiver during Unwind. The authority to continue this process is discontinued after June 30, 2025. As an alternative Colorado will explore what options are available in PEAK to make the Reconsideration Period easier for members to utilize when their renewals or other required documentation is returned late. |
| 21 | Managed Care Plan Auto-Reenrollment Strategy | Extend automatic reenrollment into an MCO to up to 120 days after a loss of Medicaid coverage. | Blanket authority discontinued after June 30, 2025. | There is no regulatory authority to extend the automatic reenrollment period. Under section 1903(m)(2)(H)(ii) of the Act and 42 C.F.R. § 438.56(g), states may require that Medicaid managed care contracts provide for automatic reenrollment into a beneficiary’s original plan for individuals who are enrolled into Medicaid after a loss of Medicaid coverage for two months or less. | Colorado did not select this e(14) waiver during Unwind. The authority to continue this process is discontinued after June 30, 2025. Colorado already reenolls members into their previous MCO if the break in enrollment if less than 60 days. |
| 22 | Exception to timely determinations | Delay procedural terminations for beneficiaries while the state conducts targeted renewal outreach | Concurrence discontinued after June 30, 2025. | The exception to timely determinations of eligibility at 42 C.F.R. § 435.912(e) permits states to exceed the timeliness standard established in accordance with paragraphs (b) and (c) of that section when there is an administrative or other emergency beyond the agency’s control. In the May 9, 2024, CIB,22 CMS announced that the unprecedented volume of renewals during unwinding warranted the continued use of this exception for renewals initiated through June 30, 2025, and that states may continue to rely on the timeliness exception to delay a procedural disenrollment for up to three months while the state conducts targeted outreach to encourage the As states return to regular operations, CMS’s broad concurrence with application of this option will not continue after June 30, 2025, as states are expected to have made significant progress in their efforts to resume routine operations (e.g., reduction in backlog of pending renewals, completion of work towards system compliance with federal renewal regulations). However, to achieve a similar result, states can build additional time into their renewal processes by adjusting the timing of renewal notifications to provide beneficiaries additional time to return their renewal form and by conducting targeted outreach to beneficiaries at risk of losing coverage for procedural reasons. If a state experiences an administrative or other emergency (e.g., natural disaster affecting all or parts of the state, such as a hurricane, flood, or wildfire) beyond the agency’s control and the state believes the circumstances meet the conditions to apply the exception at 42 C.F.R. § 435.912(e) such that the state would be justified in delaying procedural terminations in order to conduct targeted outreach, CMS strongly recommends that the state seek CMS concurrence to use the exception. | Colorado did select this e(14) waiver during Unwind for LTSS members due to systems issue not related to Unwind. The authority to continue this process is discontinued after June 30, 2025. Colorado will request a new authorization to extend our policy through December 2025. This will provide an additional two months of coverage for LTSS members and allows more time to complete the renewal process for LTSS members. |