The COVID-19 pandemic created havoc for healthcare providers, causing intensive care units and emergency departments to overflow. Staff shortages driven by infection and burnout were endemic. In January 2021, the Secretary of Health and Human Services declared a public health emergency (PHE) in response to the impact of the pandemic on our healthcare systems and patients. To help alleviate care payment (and other) issues during the pandemic, Congress passed the Families First Coronavirus Response Act in March 2020. This law created the Continuous Enrollment Requirement (CER), which dictates that in exchange for additional funds, states cannot require Medicaid and CHIP redetermination.

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