CMS Issues Guidance on 100% FMAP for UIOs

September 1, 2021

Source: National Council of Urban Indian Health

Through the American Rescue Plan Act of 2021 (ARP), the Biden-Harris Administration has committed to increasing the capacity of the Medicaid program deliverables, enabling care delivery to millions of eligible individuals. This initiative is a key foundation in addressing the health disparities and inequities that unjustly impact our most at risk populations and is the front line of reducing incidence of disease and health system burden.

On August 30, 2021 the Centers for Medicare and Medicaid (CMS) released guidance around the temporary increases to federal matching funds (FMAP) under sections 9811, 9814, 9815, and 9821 of the ARP.

The new guidance highlights Medicaid and CHIP coverage for COVID-19 testing, diagnostic, and vaccination access in varied settings (section 9811 & 9821) along with 100% FMAP for COVID-19 vaccine administration. This match is inclusive to all state expenditure for COVID-19, even when a COVID-19 vaccination is provided as part of bundled care, such as a nursing facility or federally qualified health center (FQHC). Under the ARP, states are required to cover COVID-19 vaccination costs for Medicaid and CHIP beneficiaries at no cost. Thusly, removing financial barriers that could otherwise prevent diagnosis and prevention.

Additionally, the ARP provides a temporary increase in FMAP for Medicaid expenditures in states that newly extended coverage to qualifying adults (section 9814). There are 39 states, including the District of Columbia, that will qualify for the 90% federal matching funds through the Affordable Care Act (ACA) in addition to the 5% point increase in federal matching for certain Medicaid expenditures.

Lastly, section 9815 of the ARP temporarily allowed 100% FMAP for state expenditures for Medicaid services received through Urban Indian Organizations (UIOs) and certain Native Hawaiian Health Centers (NHHCs). This change edits 1905(b) of the act, which previously provided 100% FMAP for “amounts expended as medical assistance for services which are received through an IHS facility whether operated by the IHS or by an Indian tribe or tribal organization (as defined in section 4 of the Indian Health Care Improvement Act).” Retroactive FMAP began on April 1, 2021 and will continue through March 31, 2023. Currently, ARP language and amendments authorize 100% FMAP for service expenditures for all Medicaid beneficiaries seeking care at UIOs and NHHCs.

NCUIH is paying close attention to the fact that states have the discretion to set and amend Medicaid provider rates if the care is consistent with the economy and quality of care. In this case, a state must demonstrate capacity to sufficiently enlist enough providers to support the general population in a geographic area. In this instance, states could seek technical assistance from CMS if they felt adjusting their reimbursement rate from UIOs was appropriate.