CMS Says No Extra Funding for States That Do Not Make Full Medicaid Expansion and Offers Other ACA Guidance
Client Alert | 1 min read | 12.11.12
On December 10, 2012 the Center for Consumer Information and Insurance Oversight (CCIIO), a component of the Centers for Medicare and Medicaid Services (CMS), published a "Frequently Asked Questions on Exchanges, Market Reforms and Medicaid." Among the more notable guidance in the FAQ, CCIIO clarified that if states pursue a partial expansion of Medicaid coverage, rather than the full expansion to 133% of the federal poverty level, then the state will not receive federal matching funds for that partial expansion. That is, full expansion is a condition precedent to federal matching funds—there are no federal matching funds for partial expansions. The FAQ also noted that a state that participates in the Medicaid expansion may elect to drop the coverage at a later date. Additionally, the FAQ provides guidance on, inter alia, the interplay between federally-facilitated exchanges and states, multistate plans, consumer outreach and eligibility, the Medicaid expansion, and coordination between the exchanges and other programs. Click here for the full FAQ.
Insights
Client Alert | 1 min read | 04.18.24
GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings
On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS). Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:
Client Alert | 4 min read | 04.18.24
Client Alert | 6 min read | 04.16.24
Navigating the AI Intellectual Property Maze - Key Points From Congressional Hearing
Client Alert | 5 min read | 04.15.24
Making the EU Courts More Efficient for Trade-Related Decisions