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Comments on Revisiting Medicaid Maintenance of Effort Flexibilities

CMS reopened the comment period on an interim final rule originally published in November 2020 that provided additional flexibility to states to meet the maintenance of effort (MOE) requirement under the Families First Coronavirus Response Act to receive the 6.2% enhanced federal match. CMS is considering rescinding this flexibility and requested feedback on its approach. Our response highlighted the coverage implications current MOE flexibilities have for LTSS beneficiaries as well as additional state administrative burden. Read our response here.


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