Medicaid Maintenance of Eligibility (MOE) Requirements: Issues to Watch

Appendix Table 1: Key Dates
Policy/Flexibility Description Start Date End Date
Enhanced Federal Medicaid Assistance Percentage (FMAP) A temporary 6.2 percentage point increase in the regular federal matching rate. To receive the enhanced match states must comply with maintenance of eligibility requirements. January 1, 2020 End of the quarter in which the PHE ends
Continuous Coverage Requirement Requires states to provide continuous eligibility for those enrolled prior to or during the emergency, regardless of changes in circumstances, unless the individual requests termination or ceases to be a resident. March 18, 2020 End of the month in which the PHE ends
Other Maintenance of Eligibility (MOE) Provisions States cannot implement more restrictive eligibility policies or procedures and states cannot increase Medicaid premiums. States also must cover coronavirus testing and COVID-19 treatment without cost-sharing. States also cannot increase political subdivisions’ contributions to the non-federal share of Medicaid costs. January 1, 2020 and March 1, 2020 (for political subdivision contributions) End of the quarter in which the PHE ends
Disaster-Relief SPA Allows states to make temporary changes to address eligibility, enrollment, premiums, cost-sharing, benefits, payments, and other policies differing from their approved state plan during the COVID-19 emergency. States may not make changes that restrict or limit payment, services, or eligibility or otherwise burden beneficiaries and providers. January 1, 2020 (using Section 1135 waiver authority) or later date elected by state End of public health emergency or earlier date elected by state
Traditional SPA Allows states to amend their Medicaid state plans, which govern program elements such as coverage groups, covered services, provider reimbursement methodologies, and administrative activities. 1st day of quarter in which SPA is submitted to CMS or later date elected by state Continues until subsequently amended or terminated
Section 1115 Demonstration Waiver Allows states to operate  Medicaid programs without regard to specific statutory or regulatory provisions to furnish medical assistance in a manner intended to protect, to the greatest extent possible, the health, safety, and welfare of individuals and providers who may be affected by COVID-19. March 1, 2020 or later date elected by state and approved by CMS 60 days after public health emergency ends or earlier date approved by CMS
Issue Brief

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