HMP Global October 16, 2025
On September 30, 2025, the Centers for Medicare & Medicaid Services (CMS) released State Medicaid Director Letter (SMD) #25-003, revising how section 1903(v) of the Social Security Act applies to Medicaid managed care payments for noncitizens ineligible for full Medicaid benefits. The updated interpretation limits federal financial participation (FFP) to payments for actual care and services rendered for emergency medical conditions, marking a significant shift in program integrity oversight.
According to the letter, CMS “believes it is reasonable and prudent to interpret the emergency Medicaid provision under section 1903(v) of the Act to apply only to specific payments made for care and services necessary for the treatment of an emergency medical condition actually furnished…to aliens ineligible for full Medicaid benefits.”...
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