CMS has released new guidance for states that are not yet done with the unwinding. Due to the unprecedented nature of the unwinding – exacerbated by workforce challenges and resulting in an uneven and unsustainable renewal volume in many states –  CMS concludes that the unwinding constitutes an administrative emergency that justifies exceptions to the timely completion of Medicaid and CHIP renewals beyond the 14 months states were already given. Additional context and considerations of state options going forward were included in this slide deck.

The new deadline for completing all unwinding-related renewals for all beneficiaries enrolled in Medicaid and CHIP as of the end of the continuous enrollment condition is December 31, 2025. Beginning with renewals initiated in January 2026, all states must initiate and complete renewals in a timely manner, consistent with federal regulations as described below, and adhering to routine state processing timelines.

The CMS Informational Bulletin (CIB) outlines the timeline for completing pending renewals and/or distributing renewals to achieve an even workload in the future:

• Unwinding-related renewals – States must complete all unwinding-related renewals by December 31, 2025. This includes renewals for all individuals, including populations whose renewals may have been delayed because of flexibilities or mitigations that were implemented during the unwinding period.
• Non-unwinding-related renewals – States may continue to delay or redistribute renewals through December 31, 2025, to ensure a more even distribution of redeterminations going forward.
• All renewals initiated after January 1, 2026 – States must process periodic renewals of eligibility timely, in accordance with federal regulations, and consistent with state timelines for initiating, processing, and making final determinations at renewal.

States seeking additional time to complete unwinding related renewals and/or redistribute their caseload may do so only under the following conditions:

• States may not shorten a beneficiary’s eligibility period. The state may only delay the individual’s renewal date to a later month.
• States must not disenroll an individual whose eligibility has not been renewed since the end of the continuous enrollment requirement based on a change in circumstances; the state must conduct a full renewal first.
• States should continue to attempt to update contact information and are encouraged to notify enrollees if their renewal date is changed.

For renewals that have been pending more than six months, states have the option to: 1) use the information submitted on the form to renew eligibility until the end of the original 12-month eligibility period but not beyond; or 2) reinitiate the renewal and provide a new 12-month eligibility period for those found eligible.

While most states have completed unwinding, a handful of states have not according to this last listing from CMS. As last reported, Hawaii and South Carolina are scheduled to complete renewals this month, while North Carolina, Alaska, DC, and New York are delayed in completing the unwinding. Today’s guidance provides clarity on options these states have to address any remaining barriers to completing all unwinding-related renewals and resuming routine operations going forward.