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Association Comments on Medicaid Access Exemptions Proposal

America’s Essential Hospitals in a May 22 letter expressed concern about the effects of providing exemptions from triannual Medicaid access review plans for states with high managed care penetration.

The letter is in response to a proposed rule issued in March by the Centers for Medicare & Medicaid Services (CMS). The agency proposed to alter a 2015 final rule that directed states to ensure Medicaid fee-for-service beneficiaries have access to health care services comparable to those of a given area’s general population.

Under the proposed rule, states with a Medicaid managed care penetration rate of 85 percent or higher would be exempt from the 2015 requirements. The proposed rule also would remove access analysis requirements for provider payment reductions below certain thresholds.

In its comments, the association urged CMS to:

  • ensure access to quality care for Medicaid beneficiaries by not issuing access monitoring review exemptions to states with high managed care penetration;
  • fully assess the monitoring reviews before granting exemptions from the requirements;
  • fulfill its role as sole arbiter of adequate Medicaid provider payment rates; and
  • require states to provide more than an assurance of payment adequacy to the agency when proposing to change payment rates.

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


About the Author

Rachel Schwartz is a former policy associate at America's Essential Hospitals.

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