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Association Comments on Medicaid Access

America’s Essential Hospitals on April 11 submitted comments to the Centers for Medicare & Medicaid Services’ (CMS’) request for information regarding access to coverage and care in Medicaid and the Children’s Health Insurance Program (CHIP). The association made recommendations on Medicaid payment rates, increasing and diversifying the health care workforce, eligibility and enrollment policies, and measuring access to hospital services.


CMS should strengthen its access review requirements to ensure that states fulfill their responsibility required by Section 1902(a)(30)(A) of the Social Security Act, which requires state Medicaid programs to assure payments are sufficient to enlist enough providers to provide care and services to beneficiaries to the same extent as to the general population.

To meet the requirement, a state must document that Medicaid rates either:

  • cover the average costs incurred by providers (looking at costs by certain provider characteristic to account for providers of high-cost services, of particular subspecialties, etc.);
  • are equivalent to what Medicare would have paid; or
  • equal the prevailing commercial rates in the geographic region.

If Medicaid payments met one of these three benchmarks, rates might be high enough to increase the number of providers willing to see Medicaid beneficiaries.


CMS should authorize states to use Section 1115 demonstration authority for initiatives to develop and sustain a diverse, inclusive, and cohesive health care workforce that reflects the country’s multicultural communities, mitigates health disparities, and ensures quality and patient safety.

Eligibility and Enrollment

CMS should provide guidance and technical assistance to improve states’ ability to share and obtain beneficiary data to increase automatic renewals. Further, to encourage and support deeper partnerships between states and essential hospitals in the enrollment process, CMS could expand the use of provider donations as the nonfederal share of the cost of eligibility, outreach, and enrollment efforts by the provider. Under current regulations, provider donations only cover direct costs for outstationed eligibility workers.

Measuring Access to Hospital Services

Any consideration of hospital-specific access measures must capture access to long-term and/or expensive non-emergent care. CMS must examine rate sufficiency to ensure hospital services are equally accessible to both Medicaid patients and other patients in the community.

Contact Senior Director of Policy Erin O’Malley at or 202.585.0127 with questions.


About the Author

Julie Kozminski is a senior policy analyst at America's Essential Hospitals.

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