In a letter to the Centers for Medicare & Medicaid Services (CMS) Administrator Seema Verma, MACPAC comments on an interim final rule with comment (IFC), which adopted a new interpretation of the maintenance of effort and continuous coverage requirements that states must meet to qualify for the 6.2 percentage point increase in federal medical assistance percentage (FMAP). The IFC also describes the requirements for Medicaid coverage of COVID-19 vaccines and their administration.
The Commission is concerned that certain vulnerable populations, including pregnant women, children, and beneficiaries in the breast and cervical cancer program, will lose coverage or benefits during the pandemic. The IFC also allows states to make certain programmatic changes, such as an increase in cost sharing, and remain eligible for the FMAP increase. The Commission is concerned that changes to benefits and cost sharing could make it harder for Medicaid beneficiaries to get access to care.
In addition, MACPAC expresses concern that under the IFC, some beneficiaries whose Medicaid coverage is terminated or who are enrolled in Tier 3 coverage will not have coverage for the COVID-19 vaccine and its administration during the PHE. This could exacerbate racial and ethnic disparities in COVID-19-related infections, hospitalizations, and deaths.
Finally, the Commission urges the Secretary to give state Medicaid programs sufficient advance notice as to when the PHE will end, as state Medicaid officials need to know well in advance of when they will lose the enhanced FMAP.
