When Congress enacted the Families First Coronavirus Response Act (FFCRA) in March 2020, it included "Maintenance of Effort" (MOE) protections that would require a state to preserve existing levels of Medicaid enrollment and service coverage before the state could receive enhanced federal Medicaid funding rates for the public health emergency. With the new Interim Final Rule, the Centers for Medicare and Medicaid (CMS) tries to interpret the MOE protections as allowing a state to reduce "optional" Medicaid benefits that are critical to people with disabilities such as home and community-based services, physical and occupational services, behavioral health services, and dental and vision services during the pandemic, while still drawing down enhanced federal funds. DREDF's comment opposes both the substance of the rule as well as CMS's use of an "interim final rule" which bypasses the usual public comment processes and timeline.