RFE- Lack of functionality to reinstatement of benefit for a person with no gap in eligibility without a new application

As per the federal regulations,

Citizens can come back to agency up to 90 days (reconsideration period)
from the date they lost their benefit or fail to renew and request
benefit without requiring to fill out a new application. The agency
should be able to process their request without asking them to fill out
a new application as long as citizens are able to provide required
information. The state agency should be able to reinstate their benefit
without any gap in the eligibility.

Curam OOTB is not having this ability, the rule above applicable to
both Streamlined Medicaid and Insurance assistance programs. Curam
OOTB does not support the Manual renewal process for streamlined
Medicaid (Big Gap in OOTB). So, the following steps are for QHP Renewal
provided by Curam OOTB and the gap in the reinstatement when Citizen
fails to renew on-time. The on-time renewal failure may not be citizen
s fault, sometimes it is due to agency delay also. The Gap identified
here is the lack of Curam OOTB support in processing the reinstatement
of benefit without any gap in eligibility for the 90 days
(reconsideration period) after the failure to renew on-time.

Following gaps are identified if the citizen fails to renew on-time and
due date is passed for the renewal

- The Renewal link is disappeared from the citizen portal after the
due date and citizen not able to submit renewal form
- The sign and submit and confirm renewal links are disappeared from
the case worker portal , so that case worker can't process renewal
after the due date
- Upon CIC made after the due date by the case worker does not create
a new PDC for the new certification period .

We could not find any way to give the citizen benefit without new
application in OOTB If they failed to renew on-time , should be able to
process without any new application upto 90 days.