Letter ·
NAMD Highlights Concerns About Potential Continuous Enrollment Policy Reversion
NAMD’s response to the reopened comment period on CMS’ framework for compliance with the FFCRA’s continuous enrollment policy.
CMS recently reopened the comment period on their November 2020 interim final rule that established a tiered coverage framework for states to comply with the continuous enrollment requirement in the Families First Coronavirus Response Act (FFCRA). CMS is considering reverting to their original April 2020 interpretation of the FFCRA, which required states to maintain amount, scope, and duration of benefits.
NAMD’s response highlights serious reservations about implementing this policy reversion. Specifically, we anticipate that implementing this policy change will distract from critical state preparations for the end of the public health emergency, create confusion for individuals receiving Medicaid services, and result in unintended consequences for some members.
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