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Association Comments on Medicaid Managed Care, Access Proposed Rules

In a July 3 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals responded to the Medicaid and CHIP Managed Care Access, Finance, and Quality proposed rule.

This proposed rule included changes to state directed payment programs and provider payment analysis proposals of interest to essential hospitals. America’s Essential Hospitals urged CMS to:

  • Leverage directed payment programs to ensure sufficient payment rates to promote meaningful access to care.
  • Not require attestations of private mitigation arrangements.
  • Ensure access requirements include hospital and specialty services.
  • Not finalize capitation limits on In Lieu of Services and Settings.

In a separate letter sent July 3 to CMS, the association responded to the Ensuring Access to Medicaid Services proposed rule.

This proposed rule introduced new payment analyses to ensure access to care in the Medicaid fee-for-service program. America’s Essential Hospitals urged CMS to:

  • Include hospital services in the required comparative rate analyses.
  • Ensure sufficient payments to professionals practicing in hospital settings.
  • Provide a benchmark to ensure sufficient Medicaid rates.
  • Strengthen its criteria and state remedies for rate reductions that present a low risk of access issues.
  • Include states with high Medicaid managed care enrollment in fee-for-service rate reviews.

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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