CMS Provides Guidance to States on Enhanced Medicaid Funding During COVID-19

On March 24, 2020, the Centers for Medicare & Medicaid Services provided guidance to states concerning enhanced federal Medicaid funding during the 2019 novel coronavirus national emergency.

Section 6008 of the Families First Coronavirus Response Act provides for a possible 6.2 percent increase in the federal match (FMAP) for each state and territory. The increase will be retroactive to Jan. 1 2020. The funds are available for each calendar quarter during the public health emergency. Since the emergency was declared on Jan. 31, 2020, the increased FMAP is available for qualifying expenditures incurred on or after Jan. 1, 2020, and through the end of the quarter in which the public health emergency ends.

The increased FMAP is for medical assistance expenditures for which federal matching funds are paid ordinarily at the state-specific FMAP rate. It will not apply to administrative expenditures or to services for which a higher match rate is already drawn. For example, Community First Choice 1915(k) services are already eligible for a 6 percent increase in the federal match rate.

To receive this assistance, states and territories must meet certain criteria:

•  No Increase for Political Subdivisions: States must not require political subdivisions of the state to pay a greater portion of the non-federal share of expenditures than was required on March 11, 2020.
• Maintenance of Effort: States must maintain eligibility standards, methodologies or procedures that are not more restrictive than what the state had in place, and not charge premiums that exceed those that were in place, as of Jan. 1, 2020.
• COVID-19 Coverage: States must provide coverage without additional cost-sharing for testing, services and treatments, including vaccines, specialized equipment and therapies related to COVID-19.
• Continuous Coverage: States cannot terminate individuals from Medicaid if those individuals were enrolled in the program as of the date of the beginning of the emergency period or become enrolled during the emergency period, unless those individuals voluntarily terminate eligibility or are no longer residents of the state. If states have already terminated coverage for individuals enrolled as of March 18, states are expected to inform individuals of their continued eligibility and encourage them to contact their respective states to re-enroll.
  • Where feasible, states should automatically reinstate coverage for individuals terminated after March 18 and should suspend any terminations already scheduled to occur during the emergency period. Coverage should be reinstated back to the date of termination.
  • Individuals who continue to receive services pending an appeal of a determination of eligibility should be considered enrolled.
  • States are not prohibited from conducting regular Medicaid renewals and redeterminations or acting on reported or identified changes in circumstances.

Children’s Health Insurance Program

States do not need to maintain coverage in the Children’s Health Insurance Program (CHIP) to receive the enhanced match. However, the maintenance of effort required under the Social Security Act continues to apply.

State Attestation of Compliance           

States will not be required to submit a demonstration of compliance prior to drawing funds associated with the increased FMAP. Instead, CMS will require states to attest to their compliance. States will attest by drawing funds from the increased FMAP account.

For more information, read the Families First Coronavirus Response Act – Increased FMAP FAQs.

For a complete look at federal and state action related to the coronavirus, visit MWC’s Coronavirus (COVID-19) Facts and Resources website.