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 | 4 min read | 08.14.26
License to Hack? The White House Greenlights Private-Sector Offensive Cyber Operations
On August 12, 2026, the White House released a National Security Presidential Memorandum (NSPM), marking a seismic shift in U.S. cybersecurity policy and establishing a framework to authorize private-sector companies to conduct offensive cyber operations—historically strictly prohibited by federal law—against foreign Cyber-Enabled Transnational Criminal Organizations (CE-TCOs). It builds on an executive order issued in March 2026 that directed federal agencies to develop plans to combat cyber-crimes against Americans.
Client Alert | 4 min read | 08.13.26
Supreme Court Confirms Contractual Loss of Bargain Without Repudiatory Breach
Client Alert | 7 min read | 08.12.26
Developments in Canadian Investment Treaty Practice: New FIPA Between Canada and UAE in Force
Client Alert | 6 min read | 08.11.26
