CMS To Issue OBBB Redetermination Policy Rule In December
By Amy Lotven / September 12, 2025
KANSAS CITY -- CMS will issue a rule in December on the policy in the One Big Beautiful Bill requiring states that expanded Medicaid under the Affordable Care Act to redetermine enrollees' eligibility every six months, CMS Senior Advisor Grant Thomas told health care stakeholders during the Medicaid Health Plans of America (MHPA) conference Thursday (Sept. 11). Thomas also said that CMS will be closely tracking states’ use of automated renewal processes to ease burdens on enrollees and suggested the ex parte process will also be useful for ensuring compliance with work requirements.
The CMS advisor and former Georgia health official also clarified that the redetermination policy, effective Dec. 31, 2026, only applies to the adult Medicaid expansion, during the conference’s opening session where he also ticked through CMS’ overarching priorities, and emphasized the agency will be relying on MCOs to help implement the OBBB’s work requirements.
The more frequent redeterminations is another policy where CMS is going to be leaning on its partnerships with MCOS, Thomas said.
“We think you guys are very well positioned to help educate populations about the changes -- who it applies to, who it doesn't, the marketing outreach components that you already do, when members come up for a redetermination,” Thomas said.
According to the Congressional Budget Office, about 700,000 people will disenroll from Medicaid due to the eligibility determinations, although MHPA officials have suggested that’s likely downplaying the effect of the policy. CBO believes 4.8 million will lose Medicaid because of the work requirements.
Both policies are meant to boost program integrity, not bureaucracy, Thomas emphasized, saying, “We want to make sure that we're not creating additional burdens on individual Medicaid beneficiaries when possible.”
CMS has been hard at work doing market scans and research about ways to leverage technology including by automatically checking existing data for eligibility, or the ex parte process, for redeterminations and for compliance with work requirements, Thomas said.
“When you think about Medicaid income verification, automated income verification that supports ex parte processes and automated renewals, depending on the state, ex parte rates could be 40 to 60% and so states already have a lot of experience utilizing that for income verification and Medicaid, and so we're going to be working for it and trying to apply that to employment hours,” Thomas said. CMS is working through different technology solutions and intends to move in lockstep with states to support implementation, he adds.
CMS also plans to closely track the ex parte rates for the redetermination policy, Thomas says, noting that in many cases, individuals are not even aware that they’re up for an eligibility check because it’s happening on the back end. CMS wants to make sure implementation is as seamless as possible, “where we can promote and have program integrity, but also use technology to efficiently do so and minimize any burden on the Medicaid members,” Thomas reiterated.