Fiscal and Enrollment Implications of Medicaid Continuous Coverage Requirement During and After the PHE Ends

KFF May 10, 2022
Elizabeth Williams, Robin Rudowitz, Bradley Corallo

Early in the pandemic, Congress passed the Families First Coronavirus Response Act (FFCRA), which authorized a 6.2 percentage point increase in the federal Medicaid match rate (“FMAP”) for states that meet certain “maintenance of eligibility” (MOE) requirements, with the goal of providing broad fiscal relief to states while preventing coverage losses during the pandemic. The additional funds were retroactively available to states beginning January 1, 2020 and continue through the quarter in which the Public Health Emergency (PHE) period ends. The MOE, which includes a requirement that Medicaid programs keep people continuously enrolled, expires at the end of the month in which the PHE ends.

The end date of the PHE, most recently extended to mid-July 2022, will have significant...

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