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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 | 7 min read | 10.27.26

New Developments in DOJ Whistleblower Policies and HHS Disclosures: Key Takeaways for General Counsel, Chief Compliance Officers, and Boards

On October 20, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division announced a new whistleblower rewards initiative, the Fraud Whistleblower Incentive Program (WHIP). Assistant Attorney General Colin M. McDonald issued a directive earlier this month directing Division leadership to design and implement policies and programs that incentivize whistleblowers to bring forward credible information pertaining to fraud. The new WHIP incentive pays awards of $10,000 to $30,000 for qualifying tips at or around the time criminal charges are filed or unsealed, rather than years later at case resolution....