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Association Comments on Plan to Rescind Medicaid Access Review

America’s Essential Hospitals has told federal regulators that a proposal to rescind access monitoring review plan (AMRP) requirements will weaken oversight of Medicaid payment rates and undermine statutory assurances that rates will ensure beneficiary access to needed services.

The association’s Sept. 13 letter to the Centers for Medicare & Medicaid Services (CMS) responds to a proposed rule that would rescind the AMRPs and, instead, require states to submit information and analysis demonstrating compliance with statutory beneficiary access requirements when filing State Plan Amendments for agency approval.

By law, states must set Medicaid payment rates at levels that enlist enough providers to ensure beneficiary access to all Medicaid-covered services. CMS proposes to rescind this requirement due to states’ concerns about an undue administrative burden of conducting AMRPs. In accompanying guidance, CMS outlined its intention to initiate a comprehensive strategy to measure and monitor beneficiary access to care across Medicaid.

America’s Essential Hospitals urged CMS to:

  • adopt a comprehensive and effective strategy to carry out its oversight responsibility to ensure sufficient Medicaid payment rates;
  • ensure the hospital perspective is included in the comprehensive strategy to measure and monitor beneficiary access;
  • identify and address underpayments to hospitals; and
  • address disincentives created by Medicaid demonstration budget neutrality policies.

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


About the Author

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

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