CMS Guidance on WFTCL Eligibility Redeterminations

The Centers for Medicare & Medicaid Services (CMS) published March 6 a letter to state Medicaid directors on the implementation of the Working Families Tax Cut legislation (WFTCL's) requirement to complete eligibility redeterminations once every six months for the adult expansion group and individuals receiving coverage through a waiver-based expansion. The WFTCL requirement applies to redeterminations for this population that are "scheduled on or after January 1, 2027." Currently, states may not redetermine eligibility for these individuals more than once every 12 months.

Transitioning to a Six-Month Enrollment Period

CMS provides two options for states to transition individuals from a 12-month enrollment period to a six-month enrollment period when their renewal is already scheduled for 2027:

1. States can shorten the eligibility period for affected beneficiaries whose renewal is scheduled for 2027 to an eligibility period that is as close to a 6-month period as possible from their last eligibility redetermination. However, states electing this option cannot shorten the prior eligibility period to less than 6 months or institute a new renewal date for such individuals that is before Jan. 1, 2027.
   • For beneficiaries whose prior 12-month eligibility period begins on any date between July 1, 2026 and Dec. 31, 2026, their eligibility period will be shortened to 6 months. For example, an individual with an eligibility start date of Nov.1, 2026 would have the end date of such period shortened from Oct. 31, 2027 to April 30, 2027.
   • For beneficiaries whose 12-month eligibility period begins on any date between Jan. 1, 2026 and June 30, 2026, the state can begin eligibility determinations on Jan. 1, 2027. Once the state determines a beneficiary is still eligible for Medicaid, the beneficiary's 6-month enrollment period will begin on the date when their eligibility is renewed.
2. States also have the option not to reschedule already-set 2027 renewal dates. If the beneficiary is redetermined to be eligible for Medicaid at any point in 2027, they will transition to a 6-month enrollment period at that time.

States that elect the option to shorten the eligibility period and reschedule renewal dates must notify affected beneficiaries of the change.

Households With Different Enrollment Periods

The transition to six-month enrollment periods may result in members in the same household having different eligibility periods. States may not shorten or lengthen these eligibility periods so they align within a household. However, if a beneficiary's eligibility is being renewed and provides information that affects eligibility of other household members, such as a change in income, the state must act on the information for the affected household member and redetermine eligibility.

Contact Director of Policy Rob Nelb, MPH, at [email protected] or 202.585.0127 with questions.