RE: Medicaid Managed Care Payments & Emergency Medical Condition Coverage For Aliens Ineligible For Full Medicaid Benefits

The document was released on September 30, 2025, by the Centers for Medicare & Medicaid Services (CMS). In this document, CMS presents its updated interpretation of when states can claim federal financial participation (FFP), or matching funds, for emergency Medicaid-covered services provided to undocumented immigrants. CMS provided two options: states must either provide services through fee-for-service, or contract with prepaid inpatient health plans or prepaid ambulatory health plans on a non-risk basis where none of the costs for this population would be considered in prospective payments or administrative spending . . .