CHA submitted comments on the Centers for Medicare and Medicaid Services (CMS) Ensuring Access to Medicaid Services and Managed Care Access, Finance, and Quality proposed rules. The Access proposed rule focuses on access and quality for Medicaid fee-for-service (FFS) delivery systems and home and community-based services (HCBS). The Managed Care proposed rule aims to improve state managed care programs by expanding state and plan requirements related to access, state directed payments, in lieu of services and settings (ILOSs), medical loss ratios (MLRs) and quality.
CHA’s comments highlight issues in access, payment and the need for a stronger lens on pediatric care in both Medicaid FFS and managed care delivery systems. CHA made additional recommendations to CMS on how to improve Medicaid for children’s health and hospitals.