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.
Examining the Public Charge Proposed Rule
On October 1, the Robert Wood Johnson Foundation’s State Health and Value Strategies program hosted a webinar, facilitated by experts at Manatt Health on the long-anticipated proposed rule released by the Department of Homeland Security (DHS) on September 22. The proposed rule seeks to change how DHS determines whether immigrants—when seeking admission to the U.S., an extension of their stay, or status change to become a legal permanent resident—are “likely at any time to become a public charge” (i.e., dependent on the government for financial support). Consequentially, being determined a “public charge” may put immigration status at risk. The webinar reviewed the proposed rule and its potential impacts on consumers, states and providers. Specifically, we highlighted the key ways the proposed rule departs from current guidance, with a particular focus on the implications for Medicaid and other health-related public benefits, and how the proposed rule may impact consumers’ access to certain benefits.
Given the large number of questions received during the webinar, Manatt Health produced a Public Charge Proposed Rule: Frequently Asked Questions that condenses the questions into key categories of interest. We hope you find this resource informative and if the proposed rule is finalized, it will be important to revisit these and other questions to assess the impact of the rule on immigrants as well as states, localities, and health care providers.