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September 15, 2023

CMCS Informational Bulletin on Four Walls: Grace Period Extended through February 2025

On September 8, Deputy Administrator and Director of the Center for Medicaid and CHIP Services (CMCS), Dan Tsai, published a CMCS informational bulletin (CIB) announcing the further extension of the “four walls” grace period to February 2025. CMS’s current interpretation of the clinic benefit regulations provided in 42 C.F.R. § 440.90 prohibits Medicaid reimbursement for “clinic services” provided outside of the four walls of a facility. Without this grace period, the current interpretation prevents access to care, including home visits, telehealth, and other necessary outpatient services. The bulletin clarifies that this grace period extension applies to Tribal, IHS-operated, and state facilities. 

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