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Federal Medicaid policy change ends continued waivers for continuous eligibility

July 21, 2025
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Last week, the federal Centers for Medicare and Medicaid Services (CMS) issued notice to states that they will not approve any requests for new or continued waivers for continuous eligibility for any category of Medicaid enrollees.

Centers for Medicare and Medicaid Services (CMS) issued notice to states that they will not approve any requests for new or continued waivers for continuous eligibility for any category of Medicaid enrollees.

Mere weeks ago, we were commending Governor DeWine for rejecting the General Assembly’s repeal of the policy to implement continuous Medicaid coverage for young kids in Ohio with his veto authority on the state budget. CMS stated reason for abandoning this policy is: “expanded continuous eligibility allows some people to remain enrolled in Medicaid for a period of time, even if they are no longer qualified. As a result, states could be overpaying for coverage of individuals who would not normally be eligible for Medicaid or CHIP.”

A brief history of the Medicaid budget conversation in Ohio

Continuous Medicaid enrollment for young children was removed from the state budget bill sent to Governor DeWine. This policy was passed through the last state budget in the 135th General Assembly and was in the implementation process at the Department of Medicaid. Ohio had proposed that kids enrolled in Medicaid, ages zero to their 4th birthday, would stay enrolled without an annual redetermination, until the age the continuous coverage ends.

The Ohio House removed this policy in its version of the budget and the Ohio Senate did not add it back in. While the final legislative language included a repeal of this policy, Governor DeWine vetoed the repeal, which would have allowed Ohio to move ahead with its waiver request to CMS to implement the policy of continuous Medicaid enrollment for children. The July 17 notice from CMS clearly states that any new requests won’t be approved.

We do not want kids of parents who are work-required to get caught up in the administrivia of managing work requirements.

Why is continuous Medicaid coverage important?

Having a policy of continuous coverage for young kids is especially important considering the work requirements that are set to be implemented for the Medicaid expansion population. Ohio is in the process of implementing a work requirement already, and recent federal changes apply to a work requirement across the country. Inevitably with work requirements, individuals will lose coverage for either failure to meet the requirement, but more likely because of the administrative burden of managing a work requirement tracking process.

We do not want kids of parents who are work-required to get caught up in the administrivia of managing work requirements. Continuous coverage could have kept the youngest kids enrolled, even when their parents lose coverage.

On this policy shift, we’re not sure what comes next. We will continue to work with state and federal partners to understand the impact of these changes and what other avenues exist to make positive change. 

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