In this letter to U.S. Department of Health and Human Services Secretary Alex Azar, MACPAC comments on a proposed rule that makes multiple changes to federal oversight of Medicaid fee-for-service (FFS) payment and financing policies.
The Commission strongly supports efforts to improve the transparency of supplemental payments and promote Medicaid fiscal integrity, which have been the focus of prior Commission discussions and recommendations. In MACPAC’s March 2014 report to Congress, the Commission first recommended that CMS collect and report provider-level data on supplemental payments, and in its March 2019 report to Congress, the Commission recommended that CMS establish better process controls to improve the data used to monitor compliance with upper payment limit requirements.
However, the Commission urges CMS not to implement new limits for supplemental payments and financing arrangements at this time because CMS has not fully assessed the effects of these changes. In particular, the Commission is concerned that the proposed changes could reduce payments to providers in ways that could jeopardize access to care for Medicaid enrollees. Before proposing to substantially change payment and financing policies, CMS should collect and rigorously examine data on the potential effects of such changes on beneficiary access.