The Asian & Pacific Islander American Health Forum (APIAHF) submitted this comment letter in response to the Centers for Medicare and Medicaid Services (CMS) Interim Final Rule “Additional Policy and Regulatory Revisions in Response to the COVID-19 Public Health Emergency.

We are writing to express our deep concern about several provisions of this IFR. In a reversal of CMS’s stated policy from March to October 2020, this IFR would now allow states to impose numerous types of coverage restrictions for individuals who are enrolled in Medicaid. These provisions could particularly have a negative impact on immigrants and their families. Immigrants are essential workers, and many fulfill critical roles at the frontlines of the pandemic. Our healthcare system in particular relies heavily on immigrant workers, who account for nearly one in five health care staff and are overwhelmingly people of color.  

We also oppose allowing states to receive enhanced funding despite refusing to cover COVID-19 vaccination for some Medicaid enrollees, which could significantly impact the ability of pregnant immigrant women enrolled in the Children’s Health Improvement Program (CHIP) to obtain the COVID vaccine. We recommend that CMS withdraw these provisions.

This is an unprecedented pandemic, and Congress took unprecedented measures under the Families First Coronavirus Response Act to ensure all Medicaid enrollees, including immigrants, can access the services they need. HHS IFR is contrary to law and would dramatically impact immigrants and their families at a time when health care is more important than ever. We strongly oppose the discussed provisions of the IFR and urge HHS to withdraw these provisions immediately