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Association Urges CMS to Ensure Medicaid Payment Sustainability

America’s Essential Hospitals sent an April 28 letter to the Centers for Medicare & Medicaid Services (CMS) as part of our ongoing engagement with agency leadership on the importance of Medicaid support to our members. Particularly in the wake of the Supreme Court decision in Armstrong v. Exceptional Child, which foreclosed providers’ ability to sue in federal court to challenge inadequate payment rates, CMS’ role in protecting Medicaid beneficiary access to care through sufficient provider payments is more important than ever. And America’s Essential Hospitals offered our partnership to CMS in its work to fulfill that obligation.

The association urged CMS to adopt a holistic view of how various payment mechanisms work together to ensure the viability of essential hospitals and to preserve these options as the agency considers how to ensure adequate state support from Medicaid providers. In particular, America’s Essential Hospitals recommended that CMS focus on the following action items to ensure access to quality care and support innovation and transformation in the Medicaid Program:

  • Enforce payment adequacy provisions to ensure Medicaid beneficiaries have the same access to providers as the general population, including through finalizing a strengthened version of the equal access rule and allowing providers meaningful input into review of state payment rate proposals.
  • Permit states to mitigate remaining payment shortfalls with targeted supplemental funding, regardless of whether care is delivered through a fee-for-service system or managed care system.
  • Through Medicaid waivers, continue to permit states to provide support for uncompensated care that is draining support from key Medicaid providers.
  • Continue to support innovative efforts to incentivize high-value care by preserving and building on delivery system reform incentive payment (DSRIP) programs.

Please contact Beth Feldpush, DrPH, senior vice president of policy and advocacy, at or 202.585.0111 with any questions.


About the Author

Matt Buechner is the policy and advocacy associate for America's Essential Hospitals.

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