Unwinding the Maintenance of Effort Requirement at the end of the Public Health Emergency (PHE): The Role of Title V Programs

Authors Catalyst Center

Date 2022

Keywords Covid-19, CYSHCN, Financing, Medicaid/CHIP

Under the Families First Coronavirus Response Act, state Medicaid programs are eligible to receive an additional 6.2 percent federal funding match provided they meet certain Maintenance of Effort (MOE) requirements. One of these requirements includes providing continuous eligibility to enrollees through the end of the month in which the Public Health Emergency (PHE) ends. After the PHE expires, states will need to redetermine the eligibility of over 80 million Medicaid enrollees, including an estimated 37.3 million children.

This Catalyst Center explainer describes how the end of the MOE requirement under the PHE could impact children and youth with special health care needs (CYSHCN), and outlines specific actions state Title V programs can take to help ensure continuous coverage for CYSHCN.