An Unfunded Mandate? Medicaid Continuous Coverage Requirements and State Fiscal Burdens During COVID‐19

At the onset of the COVID‐19 pandemic, the federal government increased states' Medicaid Federal Medical Assistance Percentages (FMAPs) by 6.2 percentage points, contingent on a continuous coverage requirement that prevented disenrollment. While these policies were expected to generate offsetting fiscal effects, their realized impacts have not been quantified. We estimate that states' share of continuous coverage costs totaled $139.2 billion nationwide, about $11.0 billion less than the additional revenues through higher FMAPs, implying the policy was fully federally funded nationally. However, fiscal effects varied substantially across states, with twenty states receiving insufficient federal aid to offset their excess coverage costs.