CHA News

CHA Issues Draft Comments on Medicaid Fiscal Accountability Proposed Rule

For CEOs, CFOs, chief legal counsel, government relations executives, finance staff

This post has been archived and contains information that may be out of date.

CHA has issued its draft comments on the Medicaid fiscal accountability regulation proposed rule, which would revise the Medicaid program. Included in the Centers for Medicare & Medicaid Services’ (CMS) proposal are changes to the rules for states to finance their non-federal share of Medicaid costs and calculate their associated upper payment limit, as well as new reporting requirements.

Members are encouraged to use the draft letter to support opposition to CMS’ proposals, which would have devastating impacts on Medicaid programs throughout the nation, disproportionately targeting providers, including hospitals and health systems that serve the most vulnerable in California. CHA will provide a template letter in CHA News later this week for members to adapt and submit.

While CHA strongly supports strengthening fiscal integrity in the Medicaid program, in its comment letter CHA urges CMS to withdraw the rule in its entirety for the following reasons:

  • The impact of the proposed rule is unknown. CMS has failed to conduct a 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.

Comments are due by 2 p.m. (PT) on Feb. 1, but members should submit letters by Friday, Jan. 31. To submit comments, go to and search “CMS-2393-P.”

If you missed CHA’s member briefing about the proposed rule and would like to listen to the recording, it is available here.