Notice Issues Related to OBBBA’s Shift of Medicaid Expansion to 6 Month Redeterminations

Executive Summary

Under the Affordable Care Act, renewals for Medicaid expansion enrollees were to occur no more than once every 12 months, except when there was a change in circumstances. However, beginning January 1, 2027, OBBBA requires that states redetermine eligibility for most Medicaid expansion enrollees once every 6 months. To properly implement this change in accordance with recent CMS guidance, states will need to re-evaluate the content of their notices of adverse action and who may be entitled to them. This issue brief explains those considerations.