CHA has submitted comments on two proposed rules related to Medicaid programs. CHA encourages members to use the letters as a template to submit comments to the Centers for Medicare & Medicaid Services (CMS), which are due by 2 p.m. (PT) on July 3.
In response to the proposed rule on Medicaid managed care delivery systems (Managed Care Access, Finance, and Quality), CHA was supportive of CMS’ goals of increasing transparency, monitoring access and improving the quality of care delivered. In the letter, CHA raised concerns about several of the proposed changes regarding state-directed payments (SDPs) that would limit states flexibility and make certain SDPs untenable. CHA contended that this could have the negative effect of reducing overall provider payment and access to Medi-Cal services, which is counter to the agency’s stated objectives. CHA provided suggestions for CMS’ consideration as it finalizes the regulation.
In comments on the proposed rule on access to Medicaid services (Ensuring Access to Medicaid Services), CHA was generally supportive of overall goals of the proposals but raised concerns that certain provisions could have the potential to negatively impact access or not allow for a level of transparency and accountability necessary to inform CMS and state administrators.
CHA thanks members for their feedback, which helped inform comments.