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covid 19 medicaid funding

FFCRA Forces Impossible Choice Between Aid and Program Integrity

Naples, FL — New research from the Foundation for Government Accountability (FGA) dives into the details of the recent Families First Coronavirus Response Act (FFCRA), revealing significant legal uncertainty surrounding the allotted Medicaid funding increase.

For decades, Congress narrowly defined Medicaid’s funding and medical assistance reimbursement. Unfortunately, the FFCRA includes several requirements that directly contradict these definitions—the most troubling of which prohibits states from removing any current or incoming Medicaid enrollees from the program, even if they become ineligible or commit fraud.

Many states have laws requiring state Medicaid agencies to regularly remove ineligible enrollees, and providing benefits for individuals who are not eligible for the program does not qualify for reimbursement under existing federal statutes.

Absent binding precedent and greater clarification from Congress, many states will be forced to make the choice between ignoring their own state laws or forgoing the additional Medicaid funding.

“The COVID-19 crisis has placed already-stretched Medicaid budgets under even more financial duress, the last thing we need is more financial uncertainty manufactured by the federal government” said Chase Martin, legal affairs director at FGA and co-author of the report. “The misguided requirements outlined in the FFCRA force states to make an impossible choice between increased aid and long-term damage to program integrity.”

The full FGA report can be read here.


The Foundation for Government Accountability is a non-profit, multi-state think tank that specializes in health care, welfare, and work reform. To learn more, visit

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