Planning for The Resumption of Normal State Medicaid – Part 3 of a 3 Part Blog

HNWApplying for Medicaid Long Term Care Benefits

MedicaidPost-COVID Eligibility and Enrollment Plans

  • The CMS is requiring that each state, including NJ, develop a “post-COVID eligibility and enrollment plan” to explain how they will complete the pending applications and redeterminations that were delayed during the PHE while processing new cases within the specified timelines.
  • The plan must address how states will handle applications, verifications, changes in circumstances, and renewals.
  • This plan must also address if the state plans to retain any of the flexibilities offered during the PHE, as well as how they will address the changes that result from the flexibilities expiring. The CMS will release a model plan to serve as a guide for the states in creating their own.

The CMS requests that states take a “risk-based” approach in developing these plans, which prioritizes pending eligibility and enrollment actions for individuals “who are most likely to be no longer eligible for coverage and minimizes the extent to which coverage is provided to individuals who no longer meet eligibility criteria.” The state may choose from four different risk-based approaches:

  1. Population-Based Approach: prioritizes completing outstanding eligibility and enrollment actions for individuals who are most likely to be no longer eligible
  2. Time-Based Approach: prioritizes cases based on how long the case has been pending
  3. Hybrid Approach: combination to the population-based and time-based approaches
  4. State-Developed Approach: a state can create their own plan that prioritizes individuals who are most likely to be no longer eligible or for which there is a greater risk that ineligible individuals may remain enrolled longer

The state must specify which approach they will take in their post-COVID eligibility and enrollment plan.


This letter includes several charts that may be helpful in understanding when certain flexibilities expire, as well as what notice is required for beneficiaries when they expire. They are attached here.

If you are looking for additional details on this topic or if you require advice about your situation, please contact Fredrick P. Niemann, Esq. toll-free at (855) 376-5291 or email him at  Please ask us about our video conferencing or telephone consultations if you are unable to come to our office.

By Fredrick P. Niemann, Esq. of Hanlon Niemann & Wright, a Freehold Township, Monmouth County, NJ Medicaid Attorney

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