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Comments on Proposed Changes to MEQC and PERM

In this letter to HHS Secretary Sylvia Mathews Burwell, MACPAC comments on a June 2016 proposed rule that would update the Medicaid Eligibility Quality Control (MEQC) and Payment Error Rate Measurement (PERM) programs based on changes to Medicaid and CHIP eligibility under the Affordable Care Act.

MACPAC supported the proposed rule, which addressed many of the Commission’s previous concerns about overlap and duplication in program integrity efforts.  The Commission commended the Centers for Medicare & Medicaid Services for proposals to create clearer differentiation between PERM and MEQC and reduce redundancies between the two programs as well as administrative burden on states. The Commission said, however, that silence on many aspects of eligibility review made it difficult to determine whether the rule addressed all of the new ACA mandates. In addition, the Commission suggested that eligibility quality control information should be made public as part of the final rule, to help state and federal policymakers ensure accountability for taxpayer dollars, evaluate program effectiveness and performance, and facilitate evidence-based decision making about future program changes.