CMS Deduplicates Medicaid, CHIP Enrollment Ahead of H.R. 1 Requirements

The Centers for Medicare & Medicaid Services (CMS) released an informational bulletin Nov. 6 on Medicaid and CHIP concurrent enrollments, Ensuring Medicaid Eligibility Integrity by Addressing Concurrent Medicaid and Children's Health Insurance Program (CHIP) Enrollment Across States. The bulletin reviews states' current obligations to ensure individuals are not enrolled in multiple states' Medicaid and CHIP programs ahead of new H.R. 1 requirements to reduce duplicative enrollments.

H.R. 1 requires states to establish a process to regularly obtain address information by 2027. The law requires CMS to establish a system by Oct. 1, 2029 that states and CMS can use to prevent concurrent enrollment, in which states will submit information once a month about individuals enrolled or seeking to enroll in Medicaid or CHIP. CMS will then identify whether these individuals are already enrolled in another state and share this information with the states.

Ahead of these requirements, CMS will provide states with a one-time file with Medicaid and CHIP beneficiaries identified as potentially enrolled in another state, based on T-MSIS data. The file will include beneficiary information and enrollment dates of individuals who appeared to be enrolled in two states between June and August 2025. States will be expected to verify residency for enrollees listed in the file.

The bulletin reviews federal requirements for states to act on information indicating a change in Medicaid enrollees' residency and if this change affects Medicaid eligibility for other members of the household. If the state is paying capitated payments, CMS is encouraging states to prioritize redeterminations for individuals listed in the file in managed care before beneficiaries in fee-for-service Medicaid.

CMS also reminds states of eligibility verification procedures regarding returned mail, options for eligibility verification for individuals with continuous eligibility, and states' obligations to consider all bases of eligibility for other insurance affordability programs before providing advance notice of termination that includes the right to a Medicaid fair hearing or a CHIP review.

Contact Policy Manager Julie Kozminski at [email protected] or 202.585.0113 with questions.