If a state is using the current FUL as part of their fee-for-service (FFS) lower-of reimbursement algorithm, can the state begin using the new AMP-based FULs on April 1, 2016 without filing a SPA?

States are required to apply the ACA FULs, in the aggregate, as of the effective date of the final rule with comment, that is, April 1, 2016. A SPA is not required to begin applying the ACA FULs in the aggregate.

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