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In Letter to CMS, HCA Opposes Thresholds Exempting States from Having to Submit Monitoring Plans of Medicaid Access

HCA has submitted comments to the U.S. Centers for Medicare and Medicaid Services (CMS) urging CMS to maintain its existing requirement for states, like New York, to submit an access monitoring review plan that holds states accountable on Medicaid access to care.

Under a rule known as the “equal access provision,” states are required to set Medicaid fee-for-service (FFS) rates to ensure access to services for Medicaid beneficiaries at a comparable level to non-Medicaid FFS-insured individuals. To hold states accountable for keeping competitive rates, CMS in 2015 began requiring states to submit an access monitoring review plan (or AMRP) every three years when rate changes occur (among other factors) to fee-for-service entities like Certified Home Health Agencies (CHHAs) and other FFS providers.

A new CMS proposal, however, would exempt states like New York from this critical reporting requirement on its fee-for-service program if Medicaid rate cuts were less than four percent for one year, or six percent for two years, or if 85 percent of beneficiaries are covered by a managed care organization.

In the letter, HCA challenges CMS’s assertion that rate cuts of four percent (or six percent over two years) are “nominal,” especially “given the accumulation of reductions in past years that magnify the financial impact of even slight proposed cuts, coupled with regulatory, enrollment, contracting, labor and other state policy impacts that do not necessarily classify as cuts but would nevertheless result in more CHHAs experiencing operating losses, some CHHAs closing, and threatening access to skilled home health services throughout the state.”

At 78 percent Medicaid managed care enrollment, New York State is very close to reaching the 85 percent managed care threshold that would exempt New York from submitting an access monitoring plan. “The FFS and managed care payment systems do not exist in silos,” HCA writes. “All of these services exist in Medicaid and, therefore, warrant monitoring by states and CMS for assuring access regardless of managed care volume.”

The full letter to CMS is posted on our website at