On April 2, 2024, the Centers for Medicare & Medicaid Services (CMS) published the second part of a two-part final rule that simplifies the eligibility and enrollment processes for Medicaid, the Children’s Health Insurance Program (CHIP), and the Basic Health Program (BHP). The rule eliminates certain access barriers for children enrolled in CHIP; makes transitions between programs easier; aligns and strengthens enrollment and renewal requirements for most individuals in Medicaid; establishes beneficiary protections related to returned mail; creates timeliness requirements for redeterminations of eligibility; addresses other outdated barriers to coverage; and modernizes recordkeeping requirements.

We’ve broken down the major provisions in the regulations impacting children and families in this explainer. Importantly, as our colleague Joan Alker blogged, there are significant changes that will strengthen children’s coverage in CHIP by eliminating waiting periods that force children to go without coverage prior to CHIP enrollment and lockouts that delay re-enrollment when a family has missed a premium payment.

In a much-needed step, the rules are designed to facilitate transitions for children between Medicaid and CHIP. Going forward, Medicaid and CHIP will be required to adopt procedures to accept a determination of eligibility made by the other agency. Currently, if one program has income data from a reliable source indicating eligibility for the other program, there is no requirement for the other program to act on the data. During the unwinding, this has been a barrier to ensuring that children eligible for CHIP are seamlessly transitioned and enrolled. This is one of the several reasons why we are not seeing CHIP enrollment increase even though researchers projected that most children no longer eligible for Medicaid during the unwinding would be eligible to enroll in the state’s separate CHIP program.

These positive changes to children’s Medicaid and CHIP coverage will help eliminate insurance gaps that can be detrimental to child health and development. While the regulations become effective on June 3, 2024, states will have between 12 and 36 months to implement most changes.