ACAP Policy Recommendations to Fight COVID-19

FOR MORE INFORMATION:   Jeff Van Ness, 202-204-7515,


WASHINGTON—The Association for Community Affiliated Plans (ACAP) sent a letter to leaders of both parties in the House of Representatives and the U.S. Senate outlining a series of recommendations to help confront the COVID-19 pandemic.

The recommendations are aimed at extending health coverage to as many people as possible, streamlining administrative burden to maximize the resources brought to bear directly on COVID-19, and assuring that plans, providers and states are fairly compensated for unprecedented costs.

“Coronavirus is the most substantial and widespread threat to public health in our lifetimes,” said ACAP CEO Margaret A. Murray. “Congress has moved swiftly and in a bipartisan, bicameral way to bring resources to bear against this threat. We’re happy to offer proposals which will assure that health plans and others will be able to devote as much of their limited time and resources to fighting COVID – and set aside anything but the essentials until later.”

Among the letter’s recommendations:

Expanding Health Coverage

  • Promote the expansion of Medicaid in states that have not yet done so through enhancements of the Federal Medical Assistance Percentage (FMAP).
  • Limit short-term, limited-duration “junk insurance” plans through a temporary moratorium.
  • Provide access to comprehensive health coverage through a Federal, prospective Special Enrollment Period for Marketplace plan—coupled with a federal backstop to protect issuers from overwhelming costs associated with new mid-year enrollment.
  • Assure mandatory non-emergency medical transportation is a covered Medicaid benefit.

Streamlining Administrative Burden

  • Delay implementation of the “interoperability” rule implemented by CMS in 2019, which even under the best of circumstances would demand significant resources.
  • Prohibit implementation of the Medicaid Fiscal Accountability proposed rule until the COVID-19 crisis is over.
  • Permit D-SNPs and Medicare-Medicaid plans to substitute face-to-face care coordination activities with telephonic or telehealth care management.
  • Delay Medicare Advantage health plan audits, including risk adjustment data validation audits, during the COVID-19 pandemic.
  • Provide regulatory relief on Medicaid LTSS requirements, particularly with respect to substituting telehealth for in-person assessments, timing of assessments, and eligibility requirements.

Assure Fair, Sustainable Compensation

  • Require strong CMS oversight of Medicaid managed care rate-setting to ensure that plans receive actuarially sound rates, and prohibit waivers of actuarial soundness.
  • Require CMS to provide guidance regarding mid-year rate adjustments to account for costs related to COVID-19 for plans in Medicaid managed care, Medicare Advantage or Special Needs Plans.
  • Include the COVID-19 pandemic under the “Extreme and Uncontrollable Circumstances” policy for Medicare Advantage Star Ratings.

The letter also called on Congress to require states to maintain continuous coverage for Medicaid and CHIP enrollees for the duration of the crisis, and increase the FMAP to states by 6.2 percent. Both provisions were part of the Families First Coronavirus Response Act, which was signed into law earlier today.

The letter is available in full here.

About ACAP
ACAP represents 74 Safety Net Health Plans, which collectively serve more than 20 million people. ACAP-member Safety Net Health Plans and partners serve their communities through Medicaid, Medicare, the Children’s Health Insurance Program (CHIP), and other public health programs. For more information, visit

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