Changes to Retroactive Medicaid (Coverage for Past Medical Bills)

Retroactive coverage allows Medicaid to pay for certain medical bills from before a person is eligible for Medicaid. Today, federal rules allow coverage up to three months before the month of application. Starting in 2027, federal rules will limit coverage to up to two months before the month of application.

In Rhode Island today, retroactive coverage is currently available only for:

Most people with disabilities
Adults age 65 and older
Most people applying for long-term services and supports (LTSS), including through the Katie Beckett pathway
Pregnant people
Infants under age 1

The retroactive period is determined based on the first day of the month in which the application is received
by the state. To help avoid delays, applicants should still submit applications that are as complete as possible.

What does retroactive Medicaid cover?
Retroactive Medicaid only pays for Medicaid-covered expenses. This can include a range of medical expenses, including hospital stays, doctor visits, prescription medications, and long-term services and supports (if eligible). If the recipient is eligible for retroactive coverage, the provider will be reimbursed for eligible covered services under standard Medicaid payment procedures.

What Provider Teams Need to Know

Retroactive coverage will be limited to no more than two months before eligibility date, if the applicant requests
retroactive coverage for unpaid bills and met the eligibility requirements in those retroactive months.
Services provided more than two months before application month will not be eligible for Medicaid payment after the change takes effect.
Retroactive coverage will only pay for Medicaid-covered services at the Medicaid rate.
Nursing homes, assisted living residences, and hospitals should review admission workflows, eligibility screening processes, and billing timelines to ensure alignment with the new federal limit.
Financial counselors and application assisters should inform applicants and families about the shorter retroactive period.
Updated billing guidance and examples will be shared before the change takes effect.
If you have specific billing questions, please contact your Gainwell Representative. A list of Gainwell Representative is available at eohhs.ri.gov/providers-partners/provider-directories.

Resources

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This information reflects Rhode Island’s current understanding of H.R. 1 Medicaid changes. It is pre-decisional and iterative, pending additional guidance from federal partners.