CMS has issued a series of policy and operational materials to help states implement Section 71109. The resources address eligibility and immigration-status verification, treatment of current beneficiaries, systems and process changes, federal financial participation, Medicaid and CHIP claiming, and related data and reporting requirements.
The current federal materials include:
State Health Official Letter — April 8, 2026: policy and operational guidance for Section 71109 implementation.
Implementation Slide Deck — June 18, 2026: additional implementation detail for states.
State Implementation Tool — July 31, 2026: current state implementation support and planning material.
Eligibility Verification Guidance — July 14, 2026: CMS guidance on the Medicaid and CHIP eligibility implications of DHS termination of certain parole programs for Cubans, Haitians, Nicaraguans, and Venezuelans.
This resource links directly to CMS so readers can access the current federal source materials as they are updated. PERM Insights & Perspectives does not reproduce or alter the underlying CMS guidance.
