On January 27, 2023, the Centers for Medicare & Medicaid Services released a State Health Official (SHO) letter, “Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.” The SHO letter is the second in a series of guidance related to section 5131 of the Consolidated Appropriations Act, 2023 (CAA), which established a fixed end date for the Medicaid continuous coverage requirement, a gradual phase-down for the enhanced federal match, and new guardrails for mitigating coverage loss for individuals who continue to be eligible. This expert perspective reviews the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter.
Targeted Options for Increasing Medicaid Payments to Providers During COVID-19 Crisis
The COVID-19 pandemic has caused dramatic changes in utilization that threaten the financial stability of providers and may jeopardize access to care during and after the national emergency. The federal government acknowledged the financial challenges facing providers through supplemental funding included in the three federal stimulus bills–the Coronavirus Aid, Relief, and Economic Security Act (CARES Act); the Families First Coronavirus Response Act; and the Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020. In addition, several states submitted Section 1115 waivers requesting CMS approval to establish “disaster relief funds,” paid for with Medicaid dollars, to further assist providers. States sought out innovative strategies to leverage Medicaid authorities to support the essential and vulnerable providers on the frontlines of the pandemic.
State Health & Value Strategies hosted a webinar in which experts from Manatt Health walked through tools states can use to increase payments to providers through both fee-for-service and Medicaid managed care, despite COVID-19 driven changes to utilization. This slide deck has been updated as of August 26, 2020 to reflect more recent federal guidance and examples of specific strategies states implemented between April and August 2020.
As a companion to the webinar, Manatt Health produced a toolkit for states that identifies available tools to support safety-net providers despite substantial utilization changes resulting from COVID-19.