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Comment Letter: Proposed Rule on Service Availability and Beneficiary Engagement

In a letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure, MACPAC commented on a proposed CMS rule on ensuring access to Medicaid services. The proposed rule includes a number of provisions designed to meet the statutory obligations to ensure that Medicaid provides access to services by increasing payment rate transparency, standardizing reporting, and promoting beneficiary engagement.

Overall, the Commission supports the objectives of the rule. Since its inaugural report, the Commission has recognized the importance of ensuring access to care for Medicaid beneficiaries and more recently, has focused its attention on opportunities to address the limitations of the existing monitoring approach and made a series of recommendations on how to better monitor access in Medicaid, some of which align with the provisions of the proposed rule. The Commission also supports including beneficiaries in the design and administration of the Medicaid program, as well as the process for assessing access.

The Commission also notes some general reservations regarding state capacity to implement the proposed changes within the timeframes allotted. Given states’ current focus on unwinding activities associated with the end of the public health emergency, the Commission encourages CMS to consult with states about a realistic timeline.