Page 19

Page 19 – State Health Official Letter Federal Medical Assistance Percentage (FMAP) In this section, we describe the applicable FMAP for those individuals for whom, beginning October 1, 2026, FFP is available for full Medicaid and CHIP benefits under sections 1903(v)(5) and 2107(e)(1)(R) of the Act and under the CHIPRA 214 option, in accordance with sections 1903(v)(4) and 2107(e)(1)(Q) of the Act, as well as the applicable FMAP for emergency Medicaid, including the impact of section 71110 of the WFTC legislation on FMAP claiming. FMAP for Full Medicaid and CHIP Benefits (including under the CHIPRA 214 Option) Section 71109 of the WFTC legislation made no changes to the Act’s FMAP provisions, but it did affect for whom FFP can be claimed for full Medicaid and CHIP coverage beginning October 1, 2026.64 Beginning October 1, 2026, the FMAP for expenditures for full Medicaid and CHIP benefits and expenditure reporting for FFP-eligible noncitizens (i.e., for LPRs, Cuban/Haitian entrants, and COFA migrants) would generally remain the same as prior to October 1, 2026. Expenditures for FFP- eligible noncitizens enrolled in the state’s: • Medicaid program are claimed at the state’s regular FMAP under section 1905(b) of the Act, or other applicable FMAPs as provided in statute, on the Form CMS-64 series of expenditure reports in the MBES/CBES and are funded by title XIX for Medicaid. • CHIP program: o MCHIP are claimed under section 1905(u)(2) of the Act (including FFP- eligible noncitizens who are children up to age 19) at the state’s EFMAP on the Form CMS 64.21U series of expenditure reports and are funded by title XXI CHIP Allotments. As applicable for all MCHIP expenditures, states continue to have the option under section 115 of CHIPRA to claim their MCHIP expenditures at the regular FMAP funded by title XIX for Medicaid.65 o Separate CHIP are claimed under title XXI at the state’s EFMAP on the Form CMS-21 series of expenditure reports and are funded by title XXI CHIP Allotments. FMAP for Emergency Medicaid Because the availability of FFP for full Medicaid and CHIP benefits for certain noncitizens will be more limited beginning October 1, 2026, states may, in fact, experience an overall total increase in the number of expenditures for emergency Medicaid only coverage beginning October 1, 2026. In general, emergency Medicaid is claimed at the applicable FMAP. We note that section 71110 of the WFTC legislation added a new subsection (kk) to section 1905 of the Act that limits, beginning

64 CMCS SHO letter #10-006, “Medicaid and CHIP Coverage of “Lawfully Residing” Children and Pregnant Women” (July 1, 2010), available at: https://www.medicaid.gov/federal-policy-guidance/downloads/SHO10006.pdf. 65 CMCS SHO letter #10-005, “Applicability of Federal Matching Rates in CHIP and Medicaid” (Mar. 2, 2010), available at: https://www.medicaid.gov/federal-policy-guidance/downloads/SHO10005.pdf.