The California Hospital Association, the California Association of Public Hospitals and Health Systems, Private Essential Access Community Hospitals, Inc., the California Children’s Hospital Association and the District Hospital Leadership Forum have submitted the attached joint letter on the Centers for Medicare & Medicaid Services (CMS) proposed rule on fee-for-service access to care monitoring requirements within the Medicaid program. The proposed rule would amend the process by which states document whether Medicaid payments in fee-for-service (FFS) systems are sufficient to enlist providers to assure beneficiary access to covered care and services consistent with existing statute.
In the letter, the organizations oppose an exemption from the FFS access standards, regardless of the managed care penetration rate, as it eliminates safeguards that promote a more transparent data-driven process. The letter also outlines concerns with proposals related to an exemption for states with high managed care enrollment, exemptions for nominal rate reductions, relief from public notice of rate reductions and the need for greater CMS oversight of state Medicaid programs.
Comments on the proposed rule are due by 2 p.m. (PT) on May 22.