When the COVID-19 Public Health Emergency (PHE) ended in April 2023, the Families First Coronavirus Response Act’s Medicaid continuous enrollment condition also came to an end. The condition had allowed states to claim a temporary monetary incentive for not disenrolling persons enrolled in Medicaid during the PHE, among other conditions. When this monetary incentive disappeared, many states moved quickly to disenroll recipients from the Medicaid program. In response to this trend, the Centers for Medicare & Medicaid Services (CMS) published an interim final rule (Rule) on Dec. 6, implementing reporting requirements and enforcement authorities created by the Consolidated Appropriations Act of 2023. Read more
By Cara N. Ludwig, Knicole Emanuel, Shane M. Duer, JD, CIPP/US
