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Association Comments on Managed Care Proposed Rule

In comments on the Centers for Medicare & Medicaid Services’ (CMS’) Medicaid managed care proposed rule, the association urged CMS to allow flexibility in the managed care program, so states may continue to rely on Medicaid to ensure an accessible, high-quality health care delivery system for all.

Specifically, America’s Essential Hospitals called upon CMS to allow certain direct payments that further state-level policy goals, such as achieving population health and promoting health equity and access to care. The association also urged the agency to ensure payment rates to providers are sufficient to ensure equal access to care and that network adequacy standards allow beneficiaries to retain access to their providers of choice.

This rule is the first to propose major revisions to the managed care regulations in more than a decade, and it aims to better align the program with existing standards for commercial, health insurance marketplace, and Medicare Advantage plans.

Also proposed is the development of a comprehensive quality rating system for Medicaid managed care. In response, the association urged CMS to look to existing coalition groups, such as The Partnership for Medicaid, for guidance and input to ensure measures and methodologies in this new quality rating system are applied consistently across all programs, including fee-for-service. Further, the association urged CMS to adopt The Partnership for Medicaid’s recommendations for a comprehensive quality reporting mechanism for the Medicaid Program, including a four-step process for the system:

  • development of a federal reporting infrastructure
  • establishment of a succinct common reporting set
  • federal incentives to report
  • mandated reporting by all states.

Please contact Beth Feldpush, DrPH, senior vice president, policy and advocacy, at or 202-585-0111 with any questions.


About the Author

Zina Gontscharow is a former senior policy analyst for America's Essential Hospitals.

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