Medicaid Renewal Denied: How to Appeal

Since the end of the COVID-19 public health emergency continuous enrollment protections in early 2023, states have been conducting Medicaid redeterminations for all enrolled beneficiaries — a process called the "unwinding." More than 20 million people lost Medicaid coverage during this process through 2024, many due to administrative errors rather than genuine ineligibility. If your Medicaid renewal was denied, you very likely have valid grounds to appeal.

What Is a Medicaid Redetermination?

Medicaid requires periodic eligibility reviews — called redeterminations or renewals — to verify that enrollees still meet eligibility requirements. During the COVID-19 pandemic (March 2020 through early 2023), federal law prohibited states from disenrolling anyone from Medicaid as a condition of receiving enhanced federal matching funds. This "continuous enrollment" provision kept millions of people enrolled even if their circumstances had changed.

When the continuous enrollment requirement ended in April 2023, states were required to redetermine eligibility for their entire Medicaid population — sometimes tens of millions of people — within 12 months. This created enormous administrative challenges.

Why So Many Renewals Were Denied in Error

CMS and independent researchers found that a significant portion of the 20+ million coverage losses during the unwinding were due to procedural disenrollments — people losing coverage for administrative reasons, not because they were actually ineligible. Common causes of wrongful denials included:

• Outdated contact information: Renewal notices sent to old addresses that were never received
• Returned mail processing failures: States failed to follow up when renewal mail was returned undelivered
• Documentation requests: Enrollees were asked to provide documentation they did not know they needed or could not easily obtain
• Ex parte redetermination failures: States failed to renew eligible enrollees automatically using information already available (income data from SSA, SNAP, IRS)
• Processing backlogs: State agencies overwhelmed with case volume made errors at higher rates

CMS issued multiple corrective actions to states and required some to pause disenrollments or restore coverage to certain groups.

Your 10-Day Notice Right

Before your Medicaid coverage is terminated or reduced, you are entitled to advance notice — typically at least 10 days before the action takes effect. This notice must:

• State the reason for the action
• Explain what evidence was considered
• Tell you how to appeal
• Inform you of your right to request continued benefits while appealing

If you did not receive adequate notice, that is itself an appealable violation.

Aid Continuing During Appeal: A Critical Protection

If you request a state fair hearing before the effective date of termination, you generally have the right to have your benefits continue at the current level while the hearing is pending. This is called "aid continuing" or "continuation of benefits" pending appeal.

This right is time-sensitive: if you do not request the hearing before the termination takes effect, you may lose the right to continued benefits during the appeal. Act immediately when you receive a termination or denial notice.

The State Fair Hearing Process

Every Medicaid applicant and beneficiary has the right to a state fair hearing to challenge any denial, reduction, or termination of benefits. To request a hearing:

1. File your hearing request in writing: Submit it to your state Medicaid agency by the deadline (usually 90 days from the notice, or 10 days if you want aid continuing)
2. Request continuation of benefits: If you want benefits to continue pending the hearing, state this explicitly in your hearing request
3. Gather your documentation: Pay stubs, tax returns, proof of residency, proof of citizenship or immigration status, medical records (for disability-based eligibility), and any other documents supporting your eligibility
4. Attend the hearing: Bring your documentation and be prepared to explain why you still meet Medicaid eligibility criteria
5. Request the case file: Before the hearing, request all documents the agency used in making its decision

Common Documentation Issues to Address

• Income: If income was calculated incorrectly, bring documentation of your actual income (pay stubs, Social Security award letters, SSA benefit verification)
• Change in circumstances: If your income or household size has changed, document the change clearly
• Residency: Bring proof of your current state residence
• Returned mail: If your renewal notice was sent to an old address, explain this at the hearing and ask for the denial to be vacated on procedural grounds

Re-Applying While Appealing

You can simultaneously re-apply for Medicaid while appealing the denial. A new application starts a fresh eligibility review and may resolve the issue faster than the hearing process, particularly if the denial was based on outdated information.

Getting Help

• Legal aid: Many legal aid organizations specifically assist with Medicaid redetermination appeals. Search for your local legal aid at lawhelp.org
• SHIP counselors: For Medicare-Medicaid dual eligible individuals, SHIP counselors (shiphelp.org) can provide additional assistance
• Navigators and enrollment assisters: Federally funded navigators can help with Medicaid re-enrollment and appeals

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Related Reading:

• How to Write an Insurance Appeal Letter
• What Is Medical Necessity?
• Internal vs External Insurance Appeal