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Association Comments on Medicaid Managed Care Proposed Rule

In a Jan. 14 letter to the Centers for Medicare & Medicaid Services (CMS), America’s Essential Hospitals commended the administration’s efforts to reduce regulatory burden, increase state flexibility, and streamline managed care regulations in Medicaid and the Children’s Health Insurance Program (CHIP).

The letter was sent in response to a Nov. 8 proposed rule that, if finalized, would increase flexibility to support certain providers under managed care contracts through “directed payments” and “pass-through payments.” In the proposed rule, CMS acknowledges that requirements and review processes implemented in 2016 add burden for states and hinder their ability to tailor managed care contracts to their markets. The proposal would remove some of these requirements, which have hindered the establishment of directed payment arrangements, and allow for new pass-through payments during state transitions to managed care.

In its comments, America’s Essential Hospitals urged CMS to:

  • finalize its proposals to give states additional flexibility to achieve Medicaid policy goals through support for their essential providers;
  • ensure, when determining network adequacy for managed care plans, that Mediciad beneficiaries retain access to hospitals with a full range of linguistically and culturally appropriate services, such as essential hospitals; and
  • continue to seek input and guidance in the development of a Medicaid managed care quality rating system through a consensus-building approach that involves the public and interested stakeholders.

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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