What does the Families First Coronavirus Response Act (FFCRA) mean to me and my practice?


Q – What does the Emergency Period mean and what is the duration of this act?
A – The emergency period mentioned in section 319 of the Public Health Service Act states this act shall be active during the emergency period for a period of 90 days, unless further extended by the authorities.

Q – Does FFCRA change Medicaid Coverage?
A – FFCRA adds several new Medicaid eligibility groups for individuals that are uninsured during the COVID-19 pandemic.  Extended coverage includes

  • Retroactive eligibility period effective no earlier than March 18, 2020
    • Eligible for the extended coverage receive limited services related to testing, diagnosis of COVID-19 provided during the emergency period.

Q – What is the eligibility criteria for this group?
A – Individual must be uninsured, meaning he/she must

  • Not be eligible to receive coverage under a mandatory Medicaid eligibility group (state laws may differ)
  • Not be enrolled in Medicaid coverage.
    • Individuals receiving limited Medicaid coverage (TB, family planning, considered medically needy) would still be considered uninsured.
  • Not be insured by another federally funded health care program, like CHIP, Basic Health Program, Medicare, TRICARE and Veterans Administration, and other federal employee health plans
  • Not covered by any other group health plan or health insurance, examples of which are, employer-sponsored health insurance, retiree health plan etc.

Q – Are there any financial eligibility requirements for coverage under this newly eligible group?
A – No, there is no income or resource test for coverage.  However, other eligibility requirements include

  • Being a resident of the state
  • SSN
    • State agencies must help individuals who do not have an SSN
  • For non-US citizens, or do not have a satisfactory immigration status Federal Financial Participation (FFP) is limited to payment for services necessary for treatment for an emergency medical condition.

Q – What services are covered?
A – Services provided no earlier than March 18, 2020 are covered including

  • In vitro diagnostic testing (and administration of that test)
  • COVID-19 testing-related services

Q – Does Medicaid also cover serological tests for optional COVID-19 testing eligible group?
A – Yes.  Effective no earlier than March 18, 2020.  FDA advises that serological tests for COVID-19 meet the definition of an in vitro diagnostic product for the detection of SARS-CoV-2 virus.

Q – What are COVID-19 testing-related services?
A – Services associated with and related to the administration of an in vitro diagnostic product, or to the evaluation for purposes of determining the need for such products, such as an X-ray

Q – What is the Federal Medical Assistance Percentage (FMAP) for the services provided for the COVID19 testing group?
A – The FMAP for services provided to an individual enrolled in the COVID-19 testing group is 100 percent. The 100 percent match is only available for the testing and testing-related services provided to beneficiaries enrolled in the new COVID-19 testing group (and for related administrative expenditures); the 100 percent match is not provided for COVID-19-related testing and diagnostic services provided to individuals covered under other Medicaid eligibility groups.

Q – What benefits were added for targeted low-income children and targeted low-income pregnant women covered by CHIP?
A – Coverage of in vitro diagnostic products for the detection of SARS-CoV-2 or diagnosis of COVID-19 are covered the same way they are covered in Medicaid.  Coverage begun from March 18, 2020

Q – Are individuals covered through CHIP also exempt from cost sharing for testing related to COVID-19?
A – Yes.  FFCRA exempts from cost sharing of

  1. Any in vitro diagnostic product described above
  2. Any other COVID-19 testing-related services.

For further queries, contact us at crm@claimsmedinc.com