Stakeholders raise alarms on two CMS proposals

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Thursday, September 5, 2019

WASHINGTON – Industry stakeholders urge providers to comment on a proposal that would rescind certain Medicaid regulations regarding a state’s obligation to assess and monitor beneficiary access when requesting approval to reduce or restructure payment rates.

AAHomecare has submitted comments on CMS-2406-P2, “Medicaid Program; Methods for Assuring Access to Covered Medicaid Services-Rescission,” and NCART plans to.

“This would be a major setback, dramatically minimizing the steps that a state currently must perform to conduct a proper ‘access impact analysis’ before proposing Medicaid changes,” NCART stated in a recent bulletin.

AAHomecare argues that without the current Access Monitoring Review Plan Regulation, CMS will have insufficient information to enforce compliance with equal access requirements. Additionally, the association believes managed care organizations need specific oversight by state Medicaid programs to ensure that federal dollars being spent on this program give patients access to care.

“Contrary to the assertion that underlies the proposed rule, the AMRP does not eliminate or even hinder a state’s ability to administer its plan for medical assistance,” AAHomecare stated in its comments. “The AMRP is simply providing oversight into how states are assuring they have adequate rates and a program that ensures access. If CMS is interested in achieving a reduction in regulatory burden, it could limit the number of years of tracking rate adjustments or benefit redesign to two years.”

NCART is also asking providers to comment on another proposed rule, CMS-1713-P, which, among other things proposes a new methodology that Medicare would use to establish payment rates for new items/codes.

“While we agree a new methodology is needed, we have major concerns with this approach and data that is being proposed,” the group stated.

Submit comments through Sept. 13 for CMS-2406-P2 at https://www.federalregister.gov/, searching for proposal number. Submit comments through Sept. 27 for CMS-1713-P.