Reinvesting the American Rescue Plan Act’s Ten Percent FMAP Enhancement for Home and Community-Based Services

The American Rescue Plan Act of 2021 (ARP),1 signed into law on March 11, 2021, provides relief for Medicaid home and community-based services (HCBS) programs with scheduled, enhanced federal financing participation to offset state expenditures. The ARP defines HCBS as a host of Medicaid services and programs that are typically referenced by the Centers for Medicare and Medicaid Services (CMS). It also broadly includes some Medicaid services for participants who are not typically viewed as part of HCBS populations.2

In Section 9817 of the ARP,3 all U.S. states that currently have HBCS programs will receive a temporary 10 percent enhancement to their federal medical assistance percentage (FMAP) for the costs they incur when continuing to deliver the programs between April 1, 2021, and March 31, 2022. States must spend the enhanced FMAP funding by March 31, 2024.

Public Consulting Group (PCG) has proven approaches to help states navigate the enhanced FMAP reinvestment process. Founded in 1986, PCG is a leading public sector solutions implementation and operations improvement firm that partners with health, education, and human services agencies to improve lives. We offer a multidisciplinary approach to meet challenges, pursue opportunities, and serve constituents across the public sector.

PCG is ready to support states by:

  • Increasing and improving access to self-directed HCBS services and supports, which will optimize state funding4

  • Creating targeted efforts to transition individuals from institutions to the community

  • Assuring and improving quality in HCBS, as our firm is a QIO-Like Certified Agency

  • Simplifying monitoring/reporting for critical incident management; compliance audits; the provider-remediation process; and enhanced beneficiary risk mitigation

  • Supporting the planning process, program implementation, and operations related to building workforce capacity in the HCBS system


Our team can help states decide on the best categorical use of the enhanced FMAP funds—whether for direct services or time-limited administrative costs. The more states spend on eligible HCBS now, the more FMAP states will receive to spend on COVID-19 relief during the period of public health emergency (PHE) or capacity building in the next few years.

To learn more, access our comprehensive guide here!

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[1] American Rescue Plan Act of 2021, s 9817, Additional Support for Medicaid Home and Community Based Services During the COVID-19 Emergency<https://www.congress.gov/bill/117th-congress/house-bill/1319/text>(31 March 2021)

[2]
Two examples of typical CMS HCBS definitions include: 1) 2017 DHHS Report to President and Congress: The Money Follows the Person (MFP) Rebalancing Demonstration, https://www.medicaid.gov/sites/default/files/2019-12/mfp-rtc.pdf, pg 1; and 2) LTSS Models, Home and Community-Based Services, https://www.cms.gov/Outreach-and-Education/American-Indian-Alaska-Native/AIAN/LTSS-TA-Center/info/hcbs

[3]
American Rescue Plan Act of 2021, s 9817, Additional Support for Medicaid Home and Community Based Services During the COVID-19 Emergency<https://www.congress.gov/bill/117th-congress/house-bill/1319/text>
 
[4] “Implementation of American Rescue Plan Act of 2021 Section 9817: Additional Support for Medicaid Home and Community-Based Services during the COVID-19 Emergency,” Centers for Medicare & Medicaid Services, Department of Health & Human Services, accessed May 19, 2021, https://www.medicaid.gov/federal-policy-guidance/downloads/smd21003.pdf