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Comment Letter: Medicaid Program and CHIP; Mandatory Medicaid and Children’s Health Insurance Program Core Set Reporting

In a letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure, MACPAC commented on a notice of proposed rulemaking on Medicaid Program and CHIP: Mandatory Medicaid and Children’s Health Insurance Program (CHIP) core set reporting. The proposed rule establishes key requirements for mandatory state reporting of the child core set, adult core set behavioral health measures, and the core sets for health homes.

MACPAC noted that the core set measures provide an important opportunity for states and CMS to collect consistent information on a uniform set of measures. The measures can be used to identify trends in quality, disparities that must be addressed, and opportunities for improvement. Currently, core set reporting is optional for states.

In its letter, MACPAC expressed concern that the proposed rule lacks the specificity states require to prepare for reporting the fiscal year 2024 core set. MACPAC also called on CMS to issue timely guidance that details the required measures and their technical specifications, and that gives states as much lead time as possible.

MACPAC supports the proposed requirement that states report on children enrolled in separate CHIP and Medicaid separately, but using the same data collection and reporting methods. In addition, MACPAC also supports counting pregnant individuals enrolled in separate CHIP, including those covered under the unborn child option. Given poor health outcomes for pregnant individuals, particularly among people of color, a complete picture of health quality and outcomes of those served by Medicaid and CHIP is needed and may help to identify opportunities for federal and state intervention.

Finally, MACPAC urged CMS and the Secretary of the U.S. Department of Health and Human Services to continue providing technical assistance to states to report the core set measures.