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Medicaid CMS-64 FFCRA Increased FMAP Expenditure Data Collected through MBES

On January 31, 2020, Health and Human Services (HHS) Secretary Alex M. Azar II declared a public health emergency under section 319 of the Public Health Service Act in response to the 2019 novel coronavirus (COVID-19). On March 18, 2020, the President signed into law the Families First Coronavirus Response Act (FFCRA). 

  • Section 6004 of the FFCRA added a new optional Medicaid eligibility group for uninsured individuals during a public health emergency, referred to herein as the COVID-19 testing eligibility group. Section 6004(a)(3)(D) specifies that the federal medical assistance percentage (FMAP) will be 100 percent for expenditures for covered services provided to beneficiaries under the new optional eligibility group added at section 1902(a)(10)(A)(ii)(XXIII) of the Social Security Act (the Act). Additionally, 100 percent match is available for administrative costs related to the provision of these services.   
  • Section 6008 of the FFCRA provides for a temporary 6.2 percentage point FMAP increase to each qualifying state and territory’s FMAP under section 1905(b) of the Act, effective beginning January 1, 2020 and extending through the last day of the calendar quarter in which the public health emergency declared by the Secretary of HHS for COVID-19, including any extensions, terminates. 

January 1, 2020 was the earliest that states could claim the increased FMAP under the FFCRA, and March 18, 2020 was the earliest date a state could provide coverage to the optional testing group. Accordingly, some states began reporting expenditures related to sections 6004 and 6008 through the Medicaid Budget and Expenditure System (MBES) on the Form CMS-64 for the quarter ended March 31, 2020. 

We intend to post summary level preliminary expenditure information related to these FFCRA provisions for each state to this page on a regular basis, approximately 6 months following the end of a quarter.  As described below, states may make prior period adjustments to previously reported expenditures. When posting a new quarter of preliminary expenditure data, we will also update the previously posted quarters.

On a quarterly basis, states report summarized Medicaid expenditures on the Form CMS-64, which serve as the basis for the amount of FFP paid to states to fund the Medicaid program. As part of their submission, states certify that their reported expenditures are actual expenditures allowable under federal requirements. States have up to two years, and occasionally longer, to report expenditures on the Form CMS-64. Generally, states submit State Medicaid expenditure reports to CMS within 30 days following the end of each quarter (e.g., the expenditure report for January 1, 2020 – March 31, 2020 was due April 30, 2020).  However, some states submit their expenditure reports later, sometimes due to systems or other issues within the state.

This expenditure data may be not representative of the total amount of federal financial participation (FFP) associated with section 6004 and 6008 of the FFCRA from January 1, 2020 through June 30, 2020 for a number of reasons. Specifically:

  • States generally report expenditures based on the date of payment, not the date of service. 
  • States may report additional expenditures applicable to this service period up to two years (possibly more) after the date of original service payment.
  • States may increase or decrease reported expenditures through prior period adjustments.
  • Some states may have not certified expenditure reports for this period.
  • CMS is in the process of conducting oversight activities relating to these expenditures.