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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 | 10 min read | 07.08.26

Proactive Compliance in Health Care: “Getting Ahead” of Enforcement in 2026 and Beyond

As federal and state regulators alike continue to tout holding health care organizations accountable for alleged fraud, waste, and abuse as a top priority, ensuring compliance and minimizing enforcement risk has never been more imperative — or more challenging. Health care organizations operate at the intersection of rapid technological changes and within an increasingly complex regulatory landscape, where the rules governing scrutinized areas such as privacy, AI, billing integrity, and strategic transactions are being written, rewritten, and enforced in real time. Treating compliance as a periodic documentation exercise is simply not an option. Today, an effective risk mitigation strategy must be grounded in two complementary elements: a thorough understanding of evolving regulatory obligations and a candid internal assessment of potential points of exposure....