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CHA Comments on Medicaid Fiscal Accountability Proposed Rule, Hospitals Encouraged to Comment

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Today, CHA submitted comments on the Medicaid fiscal accountability proposed rule issued by the Centers for Medicare & Medicaid Services (CMS). CHA thanks members for their input, which helped inform our comments, and for taking time to submit individual comment letters. There is still time to submit letters, which must be received by 2 p.m. (PT) tomorrow.

If finalized, the proposed rule would fundamentally change how Medicaid is financed, resulting in cuts to the program that would decrease coverage and limit access to care for Medi-Cal beneficiaries.

In the letter, CHA urges CMS to withdraw the rule in its entirety for the following key reasons:

  • The impact of the proposed rule is unknown. CMS has failed to conduct rigorous regulatory impact analysis for the proposed rule, putting access to care for Medi-Cal beneficiaries at risk.
  • CMS is operating beyond its existing statutory authority and proposing broad discretion with no clear criteria for approvals, creating a black box and uncertainty for states.
  • The proposal creates pressure on state and local communities to increase taxes to maintain support for the Medi-Cal program.
  • The proposed rule runs contradictory to the administration’s goals of reducing administrative burden.

There is still time to submit letters. CHA has provided a short template for use in describing the impact such cuts would have on your organization. CMS will accept comments until 2 p.m. (PT) on Saturday, Feb. 1. To submit comments, go to  and search “CMS-2393-P.”