Continuous Coverage Unwinding Period Guidance

The following guidance is to be used for the Continuous Coverage Unwinding (CCU) period- June 2023 through May 31, 2024. Department of Health Care Services (DHCS) requires counties to complete a Medi-Cal renewal for all individuals at their next scheduled renewal in the CCU period and not take negative action outside of the annual renewal period in most cases. The first eligibility month that a negative action or discontinuance can occur due to renewal processing is July 2023.

Important: On December 18, 2023, DHCS extended the use of all unwinding waivers and flexibilities past the end of the unwinding period and through December 31, 2024.

All existing Medi-Cal policies can be found in their respective handbook chapters.

Medi-Cal Annual Renewals and Changes in Circumstance

Medi-Cal annual renewals will be processed at their next scheduled renewal during the CCU period. A change in circumstance (CIC) that occurs outside of the scheduled renewal can only be processed if at least one of the existing household members receives a positive change to their Medi-Cal benefit. If a change report does not positively impact at least one of the existing household members, the report must be documented and the county will process the case at the next scheduled renewal. The change report details may be used to assist with the ex-parte review at renewal if applicable.

A change reported after a processed annual renewal will follow normal change reporting and CIC processing guidelines regardless of the eligibility results. The household has met its CCU period renewal requirement and the no negative action policy no longer applies.

ExampleExample

A July 2023 Medi-Cal renewal was processed resulting in continued Medi-Cal eligibility. The household met its CCU period renewal requirement. In September 2023, the recipient reports an increase in income that results in a negative eligibility determination for Medi-Cal. Eligibility for all Medi-Cal programs was explored and the individual is now eligible for a Covered CA subsidized program. The discontinuance for Medi-Cal is authorized, all applicable NOA's are provided and the individual is notified of their Covered Ca eligibility.A July 2023 Medi-Cal renewal was processed resulting in continued Medi-Cal eligibility. The household met its CCU period renewal requirement. In September 2023, the recipient reports an increase in income that results in a negative eligibility determination for Medi-Cal. Eligibility for all Medi-Cal programs was explored and the individual is now eligible for a Covered CA subsidized program. The discontinuance for Medi-Cal is authorized, all applicable NOA's are provided and the individual is notified of their Covered Ca eligibility.

Note: Individuals must be assessed for all applicable Medi-Cal programs by the Medi-Cal hierarchy. If the individual is not eligible for any other Medi-Cal program, the individual must be assessed for consumer protection programs, transitional Medi-Cal coverage, and Covered California plans.

Exceptions to the No Negative Action Policy

The exceptions to the no negative action policies continue to exist. Individuals who meet the below criteria may have a negative action processed anytime during the CCU period:

• Individuals who are reported to be deceased,
• Individuals who are no longer a resident of the state,
• Individuals who request voluntary discontinuance from Medi-Cal,
• Non-MAGI Medi-Cal individuals moving from a non-Long Term Care (LTC) aid code into an LTC aid code,
• LTC SOC increases,
• Children moving from no premium to premium aid code,
• Individuals erroneously approved due to administrative error limited to EW or Covered CA Service Center Representative data entry error (not client data entry errors), fraud at application, and fraud at redetermination before March 18, 2020.

Adding A Person to an Existing Case Outside of the Medi-Cal Renewal Period

Adding an individual to an existing case outside of a renewal period is considered a CIC and no negative action may be taken to the existing household members unless adding the person results in a positive change for at least one of the existing household members.

ExampleExample

An individual is applying for Medi-Cal benefits and is requesting to be added to an existing case. Staff determines that adding the applicant to the case would result in a positive change for at least one of the existing household members. Although the annual renewal has not been completed during the CCU period, adding the person will result in a positive change for one of the existing household members therefore the individual will be added to the case and a CIC processed for the entire household. The CCU period has now ended for this householdAn individual is applying for Medi-Cal benefits and is requesting to be added to an existing case. Staff determines that adding the applicant to the case would result in a positive change for at least one of the existing household members. Although the annual renewal has not been completed during the CCU period, adding the person will result in a positive change for one of the existing household members therefore the individual will be added to the case and a CIC processed for the entire household. The CCU period has now ended for this household.

If adding the person to the existing case does not result in a positive change to at least one of the existing household members, staff must not add the person as a CIC and instead process the case at the next scheduled renewal during the CCU period. The individual requesting to be added will require an eligibility determination and because they are applying for Medi-Cal, are subject to the 45-day application processing policy.

Note: Once the annual renewal is processed during the CCU period, the above adding a person guidance does not apply. The household has met its CCU period renewal requirement. Mandatory household members and individuals requesting to be added to an existing case must be processed by normal Medi-Cal policies.

Individuals No Longer in the Home at Renewal

Due to the continuous coverage requirement, individuals may have been reported as out of the home but a discontinuance for the individual was not allowed. These individuals may have been placed in a separate case or remained in their original case. When the scheduled renewal is processed and a primary household member reports the individual is no longer in the home and requests a discontinuance for the individual, the eligibility staff must discontinue the individual and send the appropriate notices to the individual's last known address.

If the primary applicant does not request a discontinuance for the individual no longer in the home, the individual must be moved to their own case for renewal processing and must meet all renewal verification requirements. An exparte for current information/verification's must be performed, if applicable an MC 355 sent for verifications, and a full redetermination of eligibility completed with the same renewal due dates as the original case. In this scenario, the original household's renewal is completed separately from the individual no longer in the home.

Individuals Aging Out of a Medi-Cal Program

Individuals aging out of a Medi-Cal Program will have their eligibility determined at their next scheduled renewal.

Individuals aging out and being evaluated for a Medicare Savings Program (MSP) must have their MSP and Medi-Cal eligibility determined at the time of the MSP evaluation.

Use of CalWORKs/CalFresh Report Information

Multi-program cases may have a Medi-Cal Renewal completed before it is due when the application/recertification for CalFresh/CalWORKs is complete. An incomplete CalFresh/CalWORKs report must not proceed with the processing of the Medi-Cal renewal, and the Medi-Cal Renewal will be processed at its next scheduled renewal date.

A Medi-Cal Renewal that is due at CalFresh/CalWORKs application/recertification may be processed as the Medi-Cal renewal is in the renewal period.

MEDS Alert Processing

MEDS alert processing must follow the above Medi-Cal Annual Renewal and Change in Circumstance guidance. Critical MEDS alerts and MEDS alerts containing address information must be processed to avoid access to care issues and or loss of contact. Burman Holds will be removed at the next scheduled renewal.

Undeliverable Mail Processing

Undeliverable mail processing guidance must follow Program Directive 23-01.

Transitional Medi-Cal

If applicable, individuals must be evaluated for Transitional Medi-Cal (TMC) at their next scheduled renewal.

Individuals placed into soft pause or aid code 38 as a workaround for TMC eligibility during the Public Health Emergency (PHE) must not be evaluated for TMC twice and will be redetermined for Medi-Cal eligibility at their next scheduled renewal.

A TMC report received outside of the next scheduled renewal period must not result in a negative action.

Minor Consent

Minor Consent individuals that remained on Medi-Cal due to the continuous coverage regulations must return to month-by-month Medi-Cal eligibility recertifications. Minor consent applications, recertifications, and change reports can continue to be accepted in person or by telephone.