AOF and Partners Ask CMS to Withdraw Interim Final Rule

Earlier this week AOF and a number of our partners submitted formal comments on the Center for Medicare and Medicaid Services CMS) Interim Final Rule (IFR): Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency. Provisions in the rule could lead to a reduction in Medicaid benefits and eligibility, limit access to COVID-19 vaccines and generally, contradict the intent of the Families First Coronavirus Response Act—to make sure Medicaid enrollees can access the services they need to stay healthy during this pandemic.

AOF believes all people should have access to high quality, affordable health care. The COVID-19 pandemic has elevated the role of Medicaid as a first responder in the public health and economic response of states, and Ohio’s program is no exception. More than 300,000 Ohioans have joined the Medicaid program after 1.3 million Ohioans lost not only their jobs due to the pandemic, but also health insurance for themselves and their families.

This is why Congress passed the Families First Coronavirus Response Act (FFCRA) in March, with enhanced federal funding and a requirement for states to comply with a maintenance of effort (MOE) provision. We express our significant concern about several provisions of the IFR, notably those which erode the intent of the FFCRA and enable states to impose a number of coverage restrictions through benefit limits, including the ability to refuse coverage for COVID-19 vaccination, service cuts, increased cost-sharing and result in terminations for individuals who should not be terminated, potentially exposing individuals to the loss of coverage at a critical time in our response to the virus.  

As COVID-19 continues to encompass Ohio, which has a current positivity rate over 18%, the need for consistent access to health care for routine and chronic care, as well as acute care, is obvious. Congress took appropriate measures under the Families First Coronavirus Response Act to make sure Medicaid enrollees can access the services they need to stay healthy during this pandemic. The IFR is in contradiction to the Act, the intent of Congress and to the public interest. We strongly oppose these provisions of the Interim Final Rule, and urge HHS to withdraw them immediately.

Read our full comments HERE