Comments on CMS Interim Final Rule: Medicaid Maintenance of Effort

Families USA appreciates the opportunity to provide comments on this Interim Final Rule “Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency.” This Interim Final Rule (IFR) is substantively bad policy and legally bad procedure. The IFR includes multiple elements that will hurt consumers and that countermand the stated will of Congress – including the weakening of protections for millions of Medicaid beneficiaries during the COVID-19 pandemic and a lack of a public comment process before implementing this rule. We urge CMS to withdraw this regulation in its totality to ensure that Medicaid coverage remains stable and strong throughout the COVID-19 pandemic.