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.
Timeline of Key Provisions in the American Rescue Plan Act of 2021
Patricia Boozang, Kyla Ellis, Gayle Mauser, Virginia Morgan and Allison Orris, Manatt Health
On March 11, President Biden signed an approximately $1.9 trillion COVID-19 relief bill—the American Rescue Plan Act of 2021 (“the American Rescue Plan,” ARPA). The American Rescue Plan includes myriad health care provisions, focused primarily in two areas: first, it provides funding the Biden administration requested to carry out its COVID-19 response plans; second, it enacts significant but largely temporary coverage policies.
Although all health care coverage provisions of the bill are temporary, many will have a lasting impact. This timeline provides the start and end dates for key health care provisions to help states plan for implementation and future policymaking. The provisions covered include: marketplace and commercial insurance, Medicaid and state and local funding.