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Comments on 4th COVID IFR

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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.

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