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Use of Medicaid Retainer Payments during the COVID-19 Pandemic

Since 2000, state Medicaid programs have been permitted to make retainer payments to home-and community-based services (HCBS) providers. These temporary payments are intended to preserve the financial viability of providers during disruptions in care, and are not tied to specific services used by a Medicaid enrollee.

During the COVID-19 pandemic, many states have used retainer payment authority as a source of relief for HCBS providers. As of April 12, 2021, 40 states have received Centers for Medicare & Medicaid Services (CMS) approval to expand their retainer payment policy during the COVID-19 pandemic.

This issue brief reviews how states are using retainer payments for HCBS providers during the COVID-19 pandemic. It also discusses policy issues based on a review of relevant guidance and interviews with states and other stakeholders.

The brief was originally published in April 2021 and revised in May 2021 in response to new CMS guidance on retainer payment policy during the Public Health Emergency.