The Families First Coronavirus Response Act (FFCRA), signed into law on March 18, includes an option for states to receive enhanced federal Medicaid funding. In exchange for these additional funds, states must comply with certain maintenance of effort (MOE) protections. These policies are intended to help ensure individuals can access coverage and care during the COVID-19 public health emergency (PHE). Specifically, Section 6008b(3) of the FFCRA requires states to preserve then-current enrollments and benefits through the end of the PHE: “an individual who is enrolled for benefits under such plan (or waiver) as of the date of enactment shall be treated as eligible for such benefits through the end of the month in which such emergency period ends.”
We are deeply troubled that the Interim Final Rule (IFR) seeks to undermine these critical enrollee protections. In a stark reversal of CMS’s stated policy from March to October 2020, and in direct conflict with the statute and congressional intent, the IFR would allow states to restrict coverage and terminate benefits for current Medicaid enrollees. We strongly oppose these revisions, as well as those allowing states to bypass the 1332 waiver process and to refuse to cover COVID-19 vaccinations for all enrollees. We urge CMS to immediately withdraw these harmful provisions.
Any changes to the Medicare program must aim for healthier people, better care, and smarter spending—not paying more for less. As policymakers debate the future of health care, we will provide our insights here.
Thinking ahead to Medicare's future, it’s important to modernize benefits and pursue changes that improve how people with Medicare navigate their coverage on a daily basis. Here are our evolving 30 policy goals for Medicare’s future.
You can help protect and strengthen Medicare by taking action on the important issues we are following, subscribe to newsletter alerts, or follow along on social media. Any way you choose to get involved is a contribution that we appreciate greatly.
Comments on the Fourth COVID Interim Final Rule
The Families First Coronavirus Response Act (FFCRA), signed into law on March 18, includes an option for states to receive enhanced federal Medicaid funding. In exchange for these additional funds, states must comply with certain maintenance of effort (MOE) protections. These policies are intended to help ensure individuals can access coverage and care during the COVID-19 public health emergency (PHE). Specifically, Section 6008b(3) of the FFCRA requires states to preserve then-current enrollments and benefits through the end of the PHE: “an individual who is enrolled for benefits under such plan (or waiver) as of the date of enactment shall be treated as eligible for such benefits through the end of the month in which such emergency period ends.”
We are deeply troubled that the Interim Final Rule (IFR) seeks to undermine these critical enrollee protections. In a stark reversal of CMS’s stated policy from March to October 2020, and in direct conflict with the statute and congressional intent, the IFR would allow states to restrict coverage and terminate benefits for current Medicaid enrollees. We strongly oppose these revisions, as well as those allowing states to bypass the 1332 waiver process and to refuse to cover COVID-19 vaccinations for all enrollees. We urge CMS to immediately withdraw these harmful provisions.
Reference
Recent Documents
Medicare Advantage 2025 Rate Announcement Sign-on Letter
Testimony: Legislative Proposals to Support Patient Access to Telehealth Services
Comments on the 2025 Advance Notice
Comments Supporting the Complete Rescission of the 2018 Association Health Plan Final Rule
Comments on Proposed Changes to Medicare Advantage and Part D for 2025
Statement for the Record on Medicare Advantage Marketing and the Enrollee Experience
Any changes to the Medicare program must aim for healthier people, better care, and smarter spending—not paying more for less. As policymakers debate the future of health care, we will provide our insights here.
Thinking ahead to Medicare's future, it’s important to modernize benefits and pursue changes that improve how people with Medicare navigate their coverage on a daily basis. Here are our evolving 30 policy goals for Medicare’s future.
You can help protect and strengthen Medicare by taking action on the important issues we are following, subscribe to newsletter alerts, or follow along on social media. Any way you choose to get involved is a contribution that we appreciate greatly.