Georgia Medicaid Redetermination and Unwinding: A Complete Guide to Renewal, Ex Parte, Procedural Disenrollment, and Appeals

By Brevy Care Team · Last verified May 12, 2026

Georgia Medicaid redetermination is the periodic process by which Georgia confirms whether a current Medicaid beneficiary continues to meet eligibility requirements. Federal regulation requires redetermination at least once every twelve months for most populations. The Families First Coronavirus Response Act of 2020 paused most Medicaid disenrollments during the COVID-19 public health emergency in exchange for an enhanced federal Medicaid match. The Consolidated Appropriations Act of 2023 decoupled the continuous enrollment requirement from the public health emergency, set a fixed end date in early 2023, established a phased federal match wind-down, and imposed new procedural protections on the "Medicaid unwinding." Georgia processed a large volume of unwinding renewals and a substantial share of beneficiaries were disenrolled, most of them for procedural reasons rather than substantive ineligibility. The CAA 2023 also made twelve-month continuous eligibility for children mandatory and made the twelve-month postpartum extension permanent. CMS State Health Official Letters and bulletins set implementation expectations. Section 1902(e)(14)(A) of the Social Security Act gives CMS authority to grant states procedural flexibility. The federal Reasonable Opportunity Period protects beneficiaries with citizenship or identity verification questions. Federal "fair hearing" regulations govern appeals and "aid pending" continuation of benefits. This guide translates the redetermination framework for Georgia families: how renewals work, what triggers procedural disenrollment, how to respond to a renewal packet, how to appeal, and how to navigate the post-unwinding landscape.

What Georgia Medicaid redetermination is and why it matters

Medicaid redetermination is the periodic check-in by which the state confirms that a current beneficiary continues to meet Medicaid eligibility requirements. It happens regardless of whether the beneficiary has done anything wrong. Federal law assumes that household income, household composition, residence, citizenship status, and other eligibility factors can change over time, and it requires the state to verify continued eligibility on a regular schedule.

The schedule is set by federal Medicaid regulations: redetermination at least once every twelve months for most populations. The state may renew more frequently if a reported change in circumstances warrants. But twelve months is the federal floor, applicable to almost every Medicaid pathway including MAGI-based groups (parent/caretaker relatives, pregnant individuals, children, expansion adults) and non-MAGI groups (aged, blind, disabled).

Redetermination matters because it is the moment when coverage either continues, transitions to a different pathway, or ends. For a family stable in eligibility, redetermination is invisible: the state automatically renews, and coverage continues without action by the family. For a family on the eligibility margins, redetermination can mean transitioning from one pathway to another (pregnant individual to twelve-month postpartum; child aging into a different category; aged adult crossing the ABD threshold). For a family whose income has crossed the eligibility threshold, redetermination is when coverage ends.

But redetermination also matters because of what happens when it goes wrong. When a beneficiary who is still eligible loses coverage because the state's renewal process fails them (returned mail, missed paperwork deadline, verification mismatch), that's a procedural disenrollment. Procedural disenrollment harms beneficiaries (who lose access to care), harms providers (who lose payment), and harms the state (which faces higher administrative costs to re-enroll the same beneficiary). The 2023-2024 Medicaid unwinding made the scale of procedural disenrollment painfully visible.

The federal Georgia Medicaid redetermination framework

Periodic redetermination

Federal Medicaid regulations establish the twelve-month redetermination requirement and structure it into two pathways:

Ex parte renewal: the state attempts to verify continued eligibility using existing data sources without requiring action from the beneficiary. This is the federal default and the preferred approach.

Renewal with paperwork: if ex parte verification fails, the state sends a pre-populated renewal form to the beneficiary, gives them at least 30 days to respond, and processes the renewal based on the response.

Federal regulations also address changes in circumstances, which can trigger off-cycle redetermination if the change affects eligibility.

Case maintenance and verification

A block of federal regulations governs the mechanics of ex parte renewal and verification. Key topics include:

• Cooperation with the Federal Data Services Hub (FDSH), the federal system that aggregates IRS, SSA, DHS, and other federal data for eligibility verification.
• Verification of financial information using data sources including state wage data, IRS, employer information.
• Verification of citizenship and identity.
• The Reasonable Opportunity Period for citizenship and identity verification.
• Acceptable documents for citizenship and immigration status verification.
• Twelve-month continuous eligibility for children.

Reasonable compatibility

Verification of income is structured around "reasonable compatibility" between data-source income and self-attested income:

1. Data source and self-attestation both below the eligibility threshold: reasonable compatibility, renew.
2. Data source and self-attestation both above the threshold: not eligible, terminate.
3. Data source and self-attestation conflict (one below, one above the threshold): seek additional verification before adverse action.

This structure prevents trivial verification mismatches from triggering disenrollment.

The Reasonable Opportunity Period

When state data cannot verify citizenship or identity at application or renewal, the beneficiary is entitled to a Reasonable Opportunity Period (ROP) of at least 90 days to provide acceptable documents. During the ROP:

1. The beneficiary remains enrolled in Medicaid (assuming all other eligibility criteria are met).
2. The state must provide notice of what documents are required and the consequences of failing to provide them.
3. The state cannot terminate eligibility for the citizenship or identity issue during the 90-day window.
4. If documents are not provided by the end of the ROP, the state may terminate eligibility, but the beneficiary may then submit documents to be reinstated.

The ROP is one of the most important protections for U.S. citizens (especially recent naturalizations and recent identity document changes) and lawful permanent residents, who may face brief verification delays at renewal.

Notice of agency decision

Whenever the state takes adverse action (denial, termination, suspension, reduction), it must provide written notice to the beneficiary. Notice must include:

1. The action being taken.
2. The reason for the action.
3. The specific regulation supporting the action.
4. The beneficiary's right to appeal.
5. The right to continued benefits pending appeal if requested before the effective date.
6. The right to a fair hearing.
7. The deadlines for filing an appeal.
8. The address and phone number for filing an appeal.

The notice must be provided in plain language and in writing.

Fair hearings

Federal Medicaid regulations require the state to grant a fair hearing to any beneficiary whose eligibility is suspended, terminated, or reduced. They also establish the "aid pending" right: if the beneficiary requests a fair hearing before the effective date of the adverse action, the state must continue benefits pending the hearing decision.

The fair hearing is heard by a hearing officer who is not affiliated with the agency taking the action. In Georgia, fair hearings are heard by the Office of State Administrative Hearings (OSAH) or by Georgia DCH internal hearing officers depending on the case type.

Continuous eligibility for children

States have long had the option to provide twelve-month continuous eligibility for children under age 19 in Medicaid, guaranteeing enrollment for twelve months regardless of household income changes, with limited exceptions (fraud, becoming an inmate of a public institution, death, or moving out of state).

The Consolidated Appropriations Act of 2023 made twelve-month continuous eligibility for children mandatory for all states. This was one of the most significant Medicaid stabilization measures in decades. Children's coverage continuity is associated with better outcomes, lower administrative costs, and reduced churn.

The continuous enrollment requirement and unwinding

Families First Coronavirus Response Act (2020)

The Families First Coronavirus Response Act was an early federal COVID-19 response law. It increased the federal Medicaid match for the duration of the COVID-19 public health emergency, on condition that the state maintain Medicaid eligibility for all beneficiaries enrolled when the PHE began or who enrolled during the PHE.

This was the "continuous enrollment requirement." During its multi-year run, states could not:

1. Disenroll Medicaid beneficiaries except for death, request to disenroll, or moving out of state.
2. Increase Medicaid premiums.
3. Restrict Medicaid eligibility standards or methods.

The effect was dramatic. National Medicaid enrollment grew substantially during this period, and Georgia's enrollment grew as well. Some of this growth reflected new enrollments during a recession with elevated unemployment. Much of it reflected continued enrollment of beneficiaries who would otherwise have been disenrolled at normal annual renewal.

Consolidated Appropriations Act of 2023

The Consolidated Appropriations Act of 2023 decoupled the continuous enrollment requirement from the public health emergency. The Act:

1. Set a fixed end date in early 2023 for continuous enrollment.
2. Established a phased federal match wind-down through the rest of 2023, before a return to baseline.
3. Imposed new conditions on the unwinding process to receive the wind-down match:
   • States must report renewal outcomes monthly to CMS.
   • States must demonstrate compliance with federal renewal rules.
   • States must conduct unwinding renewals over a twelve-month period.
   • States must not initiate renewals faster than the CMS-approved unwinding plan permitted.

The phased wind-down was designed to give states predictable financial support during the operational lift of returning to normal redetermination.

Early CMS planning guidance

In the run-up to the end of continuous enrollment, CMS issued a Medicaid Continuous Enrollment Provision Roadmap to states, providing early guidance on:

• Planning timeline.
• Ex parte renewal expansion.
• Returned mail processes.
• Reasonable Opportunity Periods.
• Communications and outreach.
• Workforce capacity.
• Federally facilitated marketplace transitions for beneficiaries losing Medicaid.

CMS unwinding compliance guidance

Issued just before unwinding began, additional CMS guidance provided a menu of Section 1902(e)(14)(A) flexibilities states could request:

• Expanded ex parte renewal using SNAP and TANF data.
• 90-day reconsideration periods allowing reinstatement without new application.
• Pre-populated renewal forms.
• Multiple response options (mail, online, phone, in person).
• Twelve-month continuous eligibility for adults (state option).
• Extended response timeframes.
• Streamlined supplementary verification.
• Auto-enrollment in managed care organizations without additional choice forms.

CMS mid-unwinding course correction

After some states reported high procedural disenrollment rates, CMS issued additional guidance reinforcing ex parte renewal requirements:

1. States must exhaust ex parte options before requiring paperwork.
2. Returned mail should not be treated as failure to respond.
3. States must send a second renewal notice if the first is returned undeliverable.
4. States must attempt to update beneficiary contact information through alternative data sources.

A subsequent compliance letter required states to:

1. Conduct case-level review of recent renewal denials.
2. Pause procedural disenrollments where compliance issues were identified.
3. Reinstate beneficiaries improperly disenrolled.
4. Implement system fixes.

CMS sent compliance notices to multiple states with high procedural disenrollment rates. Georgia received compliance correspondence and undertook system improvements.

Section 1902(e)(14)(A) special authority

Section 1902(e)(14)(A) of the Social Security Act permits the Secretary of HHS to allow states to implement eligibility procedures that diverge from regulatory requirements when necessary to facilitate eligibility processing or ensure continuity of coverage. CMS used this authority extensively during unwinding to grant states procedural flexibilities; virtually every state requested and received at least one such flexibility.

Georgia Medicaid unwinding experience

Timeline

Georgia began unwinding renewals in spring 2023 with a twelve-month renewal schedule. The Georgia Department of Community Health, working through the Department of Human Services Division of Family and Children Services, processed a large volume of renewals during the unwinding period.

Outcomes

Georgia's unwinding produced a substantial share of disenrollments. The dominant pattern was procedural disenrollment (returned mail, failure to respond, missing documentation) rather than substantive ineligibility. Procedural disenrollment placed Georgia in the upper range of state outcomes. Other states with comparable demographics achieved lower procedural disenrollment rates through more aggressive ex parte expansion, more proactive outreach, and stronger returned mail handling.

Disenrollment patterns

Georgia disenrollment patterns during unwinding:

• Adults (MAGI parent/caretaker, Pathways): largest share of disenrollments.
• Children: substantial disenrollments before the mandatory twelve-month continuous eligibility rule took effect.
• Pregnant individuals: largely protected by the twelve-month postpartum extension.
• ABD non-MAGI: smaller share, more complex renewals.
• Dual eligibles: largely protected by Medicare Savings Program and SSI pathways.

The Pathways to Coverage interaction

Georgia Pathways to Coverage launched during the unwinding period. Pathways is a Section 1115 demonstration providing Medicaid eligibility to non-disabled adults with income up to a federal poverty level threshold who satisfy a work, education, or community service requirement (Georgia is the only state operating a Medicaid work requirement under post-2023 federal policy).

Many adults disenrolled from continuous enrollment during unwinding were potentially eligible for Pathways. But Pathways imposes its own procedural requirements (monthly reporting of qualifying activities, online portal compliance, additional paperwork) that compounded the unwinding administrative challenges. Many beneficiaries did not transition smoothly from continuous enrollment to Pathways. Detail on Pathways eligibility, work requirements, and renewal is available in our Pathways to Coverage guide.

How ex parte renewal works in Georgia

Data sources

DCH and DHS DFCS use these data sources for ex parte verification:

1. Federal Data Services Hub (FDSH): IRS, SSA, DHS, Veterans Affairs.
2. State Wage Information Collection Agency (SWICA): Georgia Department of Labor wage data.
3. National New Hire database: federal new hire reporting.
4. SNAP records: if beneficiary is also enrolled in SNAP, their SNAP income/household data informs Medicaid verification.
5. TANF records: similar to SNAP for TANF participants.
6. Medicare and Social Security: for ABD and dual eligible beneficiaries.
7. State unemployment insurance: for recent unemployment claims.
8. Prior Medicaid case file: documents and verifications from prior eligibility cycles.

The ex parte attempt

When a renewal becomes due, the Gateway system performs an automated ex parte check:

1. Pull current household composition from case file.
2. Pull income data from FDSH, SWICA, SNAP/TANF systems.
3. Apply MAGI methodology to determine if household income remains under the eligibility threshold with reasonable compatibility to self-attested income.
4. Verify citizenship and identity status from existing records or FDSH.
5. Verify residence if data available.

If verification confirms continued eligibility on all factors, the system renews automatically. The beneficiary receives a notice confirming continued coverage, with the next renewal date.

When ex parte fails

If the ex parte check cannot confirm one or more factors, the system generates a renewal packet for paperwork renewal. Common reasons ex parte fails:

1. No current income data: beneficiary is self-employed without W-2 reporting, gig worker without 1099 reporting, or recently changed jobs.
2. Household composition unclear: addition or departure of household members not reflected in data sources.
3. Asset verification required (non-MAGI ABD only): checking and savings account balances not available through data sources.
4. Citizenship verification gap: recent naturalization, identity document change, or initial enrollment without prior verification.
5. Data conflict: data source conflicts with self-attestation by more than reasonable compatibility margin.

The paperwork renewal

The renewal packet:

1. Pre-populated with case file information.
2. Asks the beneficiary to confirm, update, or correct the information.
3. Identifies what verification is required (income documents, asset documents, citizenship documents).
4. Provides a 30-day response deadline (CMS allows states to extend this in many circumstances).
5. Provides multiple response channels: mail, online (gateway.ga.gov), phone (1-877-423-4746), in person (DFCS county office).

The beneficiary must respond by the deadline with the required information and documents. The state then completes the renewal based on the response.

What procedural disenrollment looks like

Common causes

The most common procedural disenrollment causes seen in Georgia during and after unwinding:

1. Returned mail: renewal packet sent to old address (beneficiary moved without updating). The packet is returned undeliverable. Under CMS unwinding guidance, the state should treat returned mail as a flag (not failure to respond), attempt to update contact information through alternative data, and resend the packet. In practice, this protection was inconsistently applied.

2. Failure to respond: beneficiary received the packet but did not return it. Reasons vary: didn't recognize the importance, didn't have time, lost the packet, struggled with English or literacy, faced disability or mental health barriers.

3. Missing documentation: beneficiary returned the packet but did not include required verifications (pay stubs, bank statements, citizenship documents).

4. Verification mismatch: returned documents did not reconcile with data sources (e.g., reported income lower than IRS data shows, household composition different from prior records).

5. System error: DFCS office misplaced paperwork, system glitch caused improper processing, processing delay caused premature disenrollment.

6. Pathways work requirement non-compliance: for Pathways enrollees, failure to report the required monthly qualifying activities triggers disenrollment under the Section 1115 demonstration terms.

Who is most affected

Procedural disenrollment disproportionately affects:

1. Limited English proficient beneficiaries who struggle with English-language renewal packets.
2. Recently moved beneficiaries whose mail does not reach them.
3. Working multiple jobs beneficiaries who don't have time to navigate paperwork.
4. Beneficiaries with mental health conditions, intellectual or developmental disabilities, or dementia without family or case management support.
5. Children of working parents whose parents missed the renewal deadline.

This pattern is well-documented in CMS reports, GAO reports, KFF analyses, and state-by-state advocacy reports. The pattern is not unique to Georgia, but Georgia's unwinding outcomes reflected it.

Restoration pathways

The 90-day reconsideration period

If a beneficiary is procedurally disenrolled, they can typically reapply within 90 days of disenrollment as a "reconsideration." The state processes the reconsideration without requiring a new application. If the prior eligibility is reaffirmed, coverage is reinstated retroactively to the disenrollment date, meaning there is no gap in coverage and no medical bills incurred in the meantime become the beneficiary's responsibility.

In Georgia, the reconsideration request can be made by:

1. Calling DHS DFCS at 1-877-423-4746.
2. Logging into gateway.ga.gov.
3. Visiting the DFCS county office.
4. Submitting the documentation that was missing or incorrect at the original renewal.

The 90-day window is critical. Beyond 90 days, the beneficiary typically must submit a full new application.

State Fair Hearing

Under federal Medicaid regulations, the beneficiary has the right to a fair hearing on any adverse action. The hearing must be requested within 90 days of the notice of adverse action.

Key steps:

1. Request hearing in writing or by phone within 90 days of disenrollment notice.
2. Request aid pending if requesting before the effective date of disenrollment. Aid pending continues benefits until the hearing decision.
3. Attend the hearing (in person, by phone, or by video) and present evidence.
4. Hearing officer issues a decision.
5. If the hearing officer rules in the beneficiary's favor, coverage is restored.

Georgia fair hearings are heard by the Office of State Administrative Hearings (OSAH) for most types of cases.

Reasonable Opportunity Period restoration

If a beneficiary was disenrolled for failure to verify citizenship or identity during the 90-day Reasonable Opportunity Period, submission of acceptable documents, even after disenrollment, typically results in reinstatement.

CMS complaint

For systemic unwinding issues that the state has not resolved, beneficiaries and advocates can complain to CMS Region IV at 404-562-7500. CMS used these complaints to drive subsequent compliance reviews.

Legal assistance

• Georgia Legal Services Program (1-833-457-7529): serves low-income Georgians outside metro Atlanta.
• Atlanta Legal Aid Society (404-524-5811): serves metropolitan Atlanta.
• Disability Rights Georgia (1-800-537-2329): serves Georgians with disabilities.
• Georgians for a Healthy Future (404-567-2230): health coverage advocacy.

Worked example 1: Tasha 26 Atlanta postpartum renewal during 12-month extension

Tasha is 26, lives in Atlanta, had a baby recently. She enrolled in Medicaid as a pregnant individual under the Right from the Start Medical Assistance pathway. After her baby was born, she transitioned to twelve-month postpartum coverage under the Georgia DCH State Plan Amendment, in line with the federal permanent option created by the CAA 2023. Her renewal becomes due twelve months after her baby's birth.

Tasha's circumstances at renewal:

• A modest annual income as a single parent of one child, well under the parent/caretaker threshold.
• Living at the same address.
• Citizenship and identity already verified at original enrollment.
• SNAP enrollment ongoing.

Ex parte renewal path:

1. Gateway pulls FDSH data: IRS data confirms wages consistent with self-attestation.
2. Gateway pulls state wage data: Georgia Department of Labor wage data confirms employer reporting matches.
3. Gateway pulls SNAP data: confirms household composition and address.
4. MAGI calculation: household income is well below the parent/caretaker pathway threshold.
5. Citizenship and identity already verified, so no new verification needed.

Result: Tasha is automatically renewed under the parent/caretaker MAGI pathway. She receives a notice confirming continued coverage and the next renewal date. No paperwork required.

This is what ex parte renewal is supposed to look like: invisible to the beneficiary, accurate, efficient.

Worked example 2: Eleanor 78 Macon ABD dual eligible annual redetermination

Eleanor is 78, lives in Macon, is dual eligible with Medicare and Medicaid. She qualifies for Medicaid through the Aged, Blind, and Disabled pathway. Her Medicaid covers Medicare Part B premiums (through the Qualified Medicare Beneficiary program), Medicare cost-sharing, and Medicaid-only benefits including long-term services and supports.

Eleanor's circumstances:

• A modest Social Security retirement benefit.
• A small pension.
• A modest IRA balance.
• Checking and savings accounts within ABD asset limits.

Ex parte attempt:

1. Gateway pulls SSA data: confirms SSA retirement benefit amount.
2. Gateway pulls SSA SSI data: confirms not on SSI.
3. Gateway pulls IRS data: confirms pension income.
4. Asset verification: Gateway cannot verify checking, savings, IRA balances through data sources alone.

Result: ex parte fails on asset verification. Gateway generates paperwork renewal.

Paperwork renewal:

1. Eleanor receives renewal packet ahead of the renewal date.
2. Packet asks for: financial account statements, IRA statement, vehicle ownership, household composition, residence.
3. Eleanor's daughter helps her gather documents. They return the packet within the deadline with all required statements.
4. DCH verifies assets within ABD limits.
5. Eleanor receives renewal confirmation. Coverage continues.

If Eleanor had not had her daughter's help, navigating the paperwork renewal would have been more difficult. For older adults with cognitive issues or limited family support, paperwork renewals are a common source of procedural disenrollment.

Worked example 3: Marcus 45 Albany SSI termination triggering Pathways transition

Marcus is 45, lives in Albany, has been on SSI for depression and substance use disorder. SSI eligibility automatically qualified him for ABD Medicaid. SSA performs a continuing disability review and determines Marcus no longer meets the SSI disability standard. SSI is terminated. This triggers a Medicaid redetermination.

Cascading effects:

1. SSI termination ends the automatic ABD Medicaid qualification.
2. DCH receives notice from SSA of SSI termination.
3. DCH must, before terminating Medicaid, determine if Marcus is eligible under any other Medicaid pathway.

DCH analysis:

• MAGI parent/caretaker: Marcus has no dependent children. Not eligible.
• MAGI pregnant: Not applicable.
• MAGI expansion adult: Georgia has not expanded Medicaid. Not applicable.
• ABD non-disability: Not 65 or older, not blind. Not applicable.
• Pathways to Coverage: Income under the relevant federal poverty level threshold. Potentially eligible if Marcus meets the monthly work, education, or community service requirement.

DCH sends Marcus a notice: ABD Medicaid will terminate. Marcus may apply for Pathways. To enroll in Pathways, Marcus must:

1. Apply through gateway.ga.gov or a DFCS office.
2. Complete the qualifying monthly activity hours.
3. Report monthly through the Pathways portal.

Marcus's options:

1. Pathways enrollment: if Marcus can engage in qualifying activity each month (job training, community service, education), he can enroll. But Marcus's depression makes consistent engagement difficult.
2. SSA disability appeal: Marcus can appeal the SSI termination through SSA's reconsideration and ALJ hearing process. If SSI is reinstated, ABD Medicaid is reinstated.
3. Marketplace coverage: with very low income, Marcus would qualify for the maximum Premium Tax Credit plus cost-sharing reductions through GA Access, but low-cost ACA plans typically still have utilization barriers for serious mental health and SUD treatment compared to Medicaid.
4. State Fair Hearing: appeal the DCH termination if there's a procedural argument (e.g., DCH did not adequately consider other pathways).

This is one of the most consequential transitions in Medicaid, common after SSI continuing disability reviews. The bridge from SSI Medicaid to other coverage is often broken, leading to gaps in care.

Worked example 4: Aisha 32 Savannah procedural disenrollment during unwinding

Aisha is 32, lives in Savannah, parent of two children. She was continuously enrolled through the COVID-19 PHE. DCH initiated her unwinding renewal. The renewal packet was sent to her old Savannah address (she had moved several months earlier and not updated her address with DCH or DFCS). The packet was returned to DCH as undeliverable.

Under CMS unwinding guidance, DCH should:

1. Treat returned mail as a flag, not as failure to respond.
2. Attempt to contact Aisha through alternative means (phone, email, SNAP records).
3. Resend the renewal notice to any updated address.

In Aisha's case, DCH initially proceeded with disenrollment without attempting alternative contact. Aisha discovered her coverage was terminated when she tried to fill her son's asthma prescription and was told her Medicaid was no longer active.

Recovery pathway:

1. Aisha calls DHS DFCS at 1-877-423-4746.
2. DFCS confirms termination and explains the 90-day reconsideration period.
3. Aisha files a reconsideration request, providing her current address.
4. Aisha also files a State Fair Hearing request.
5. Aisha requests aid pending continuation of benefits.
6. DFCS processes the reconsideration. With Aisha's current address and confirmation of unchanged eligibility (income, household composition), DFCS reinstates coverage retroactively to the disenrollment date.
7. The State Fair Hearing becomes moot once coverage is restored.
8. Aisha's son's prescription is covered retroactively.

Because Aisha acted quickly within the 90-day window, she avoided a permanent coverage gap. If she had waited longer than 90 days, she would have needed to submit a full new application, with possible coverage gaps and re-verification requirements.

Worked example 5: Jamil 8 Columbus 12-month continuous eligibility for children with mid-year income change

Jamil is 8, lives in Columbus, enrolled in PeachCare for Kids (Georgia CHIP). His parents enrolled him in PeachCare in February with a moderate household income for a family of three. Several months into his enrollment year, his father gets a promotion that lifts household income above the CHIP threshold.

Under the CAA 2023 mandatory twelve-month continuous eligibility for children:

1. Jamil remains enrolled in PeachCare for the remainder of his twelve-month enrollment year.
2. Income changes do not trigger mid-year disenrollment for children.
3. Jamil's parents are not required to report the income change immediately.
4. At Jamil's next annual renewal, income is reassessed. If still above the CHIP threshold, Jamil transitions off CHIP at that point.

This protection prevents the disruption that would have occurred under prior rules, where every mid-year income increase could potentially trigger disenrollment.

At the next annual renewal:

1. DCH performs an ex parte check: IRS data confirms current household income.
2. Jamil's family exceeds the CHIP threshold.
3. DCH notifies the family that Jamil is transitioning off CHIP.
4. The family receives information about marketplace coverage with APTC via GA Access.
5. The family selects a marketplace plan during the Special Enrollment Period triggered by loss of Medicaid/CHIP.

Worked example 6: Diana 65 rural Georgia dual eligible renewal across multiple programs

Diana is 65, lives in rural Georgia, recently aged into Medicare. She has ABD Medicaid coverage, Qualified Medicare Beneficiary (QMB) Medicare Savings Program status, and Part D Low Income Subsidy (LIS or "Extra Help").

Multiple renewal layers:

1. Medicaid ABD: annual, non-MAGI methodology (income and asset verification).
2. MSP QMB: annual, requires income and asset verification (slightly higher thresholds than ABD in some states).
3. Part D LIS: SSA verifies through "deeming" if Diana is on Medicaid; if she lost Medicaid, separate SSA application would be required.
4. Medicare: no renewal; once enrolled, continuous.

At her annual ABD renewal:

1. Gateway performs an ex parte check via SSA, IRS, and state wage data.
2. Income matches: modest SSA retirement, no other income. Continued QMB and ABD eligibility on income.
3. Asset verification required: Diana submits documentation of a modest checking and savings balance, no IRA, no real property beyond her primary residence.
4. DCH confirms assets within ABD asset limits.
5. Renewal complete.

If Diana's circumstances had triggered a category change (for example, an inheritance pushing assets above the ABD limit but below the MSP limit), DCH would have been required to:

1. Determine eligibility for any other pathway before terminating ABD.
2. Provide notice of category change.
3. Allow time to respond and appeal.
4. Preserve QMB and LIS status if applicable.

The complexity of dual eligible renewal is a frequent source of confusion. Detail on Medicare/Medicaid coordination is available in our Medicaid managed care plans and aged, blind, and disabled guides.

Common Georgia renewal challenges and how to address them

Challenge: I moved and didn't update my address

Update your address immediately at gateway.ga.gov, by calling 1-877-423-4746, or by visiting a DFCS county office. The state should send renewal notices to your current address. If you've missed a renewal because of a stale address, request reconsideration within 90 days.

Challenge: I got a renewal packet but I don't understand what to do

Call DHS DFCS at 1-877-423-4746 for help. The call center can walk through the packet, explain what information is needed, and accept information by phone if appropriate. Language assistance is available. You can also visit a DFCS county office for in-person help.

Challenge: I returned the packet but I'm still disenrolled

Verify that DCH received your packet. Call 1-877-423-4746. If the packet was lost, you may be able to resubmit and have the disenrollment reversed. If a verification was missing or rejected, you can typically supply additional documentation.

Challenge: I'm disenrolled but I'm still eligible

Within 90 days of disenrollment, request reconsideration through DHS DFCS. File a State Fair Hearing request simultaneously. Request aid pending if before the effective date. Submit the information that was missing or incorrect.

Challenge: I'm disenrolled because of a citizenship verification issue

You're entitled to a Reasonable Opportunity Period of at least 90 days under federal Medicaid regulations. If you've been disenrolled before the ROP expired or you can submit acceptable documents post-disenrollment, request immediate reinstatement.

Challenge: My child was disenrolled mid-year despite the 12-month continuous eligibility rule

Under the CAA 2023, children under 19 cannot be disenrolled mid-year regardless of income changes. If your child was improperly disenrolled, file a complaint with DCH (1-866-211-0950) and request immediate reinstatement.

Challenge: I'm on Pathways and missed a monthly reporting

Pathways requires monthly reporting of qualifying activity hours. Missing a report triggers warnings and potentially disenrollment. Contact DHS DFCS immediately, submit the missing report, and request reinstatement. Pathways procedural compliance is more demanding than traditional Medicaid.

How redetermination should improve

Several reforms would reduce procedural disenrollment and improve renewal outcomes in Georgia:

1. Expand ex parte renewal: use more data sources (lottery winnings, child support, gig economy data, USPS National Change of Address).
2. Strengthen returned mail handling: never disenroll based solely on returned mail; require alternative contact attempts.
3. Multilingual renewal materials: ensure renewal packets are available in the major languages spoken by Georgia Medicaid enrollees.
4. Phone renewal expansion: allow more renewals to be completed by phone with verbal attestation.
5. Pre-populated renewal forms: pre-fill more information so beneficiaries only need to confirm or correct.
6. Reduce paperwork burden: minimize the documents required, accept self-attestation where federal regulations permit.
7. Reduce timing pressure: extend response timeframes for vulnerable populations.
8. Auto-enrollment in CMOs: maintain managed care plan continuity to prevent post-renewal confusion.
9. Twelve-month continuous eligibility for adults: extend the children's 12-month continuous eligibility model to adults (state option).

Some of these reforms are within Georgia's discretion. Others require Section 1902(e)(14)(A) flexibilities from CMS. CMS continues to encourage and oversee state procedural improvements.

Brevy's role in helping families navigate renewal

Brevy's mission at brevy.com is to be the most trusted and comprehensive source of eldercare information in America. Medicaid redetermination affects everyone in Medicaid, including older adults aging into Medicare with continued Medicaid eligibility, adult children helping parents through ABD renewals, family caregivers managing renewals for loved ones with dementia, and parents managing PeachCare renewals for children. We translate the complex renewal framework into plain language and help families understand their rights and the processes that protect them.

This guide is informational and reflects publicly available federal and Georgia state policy as of May 12, 2026. It is not legal, medical, or insurance advice. Coverage rules, contact information, and policy details change. For decisions about your coverage, contact your plan, your providers, the Department of Community Health, the Division of Family and Children Services, or a qualified attorney.

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