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Commenting yesterday on two major proposed rules related to access, finance and quality in the Medicaid and Children’s Health Insurance Program managed care and fee-for-service delivery systems, AHA told the Centers for Medicare & Medicaid Services the wide-ranging regulations advance many important policies that will reshape the regulatory landscape for the Medicaid and CHIP programs. 
 
With regard to the managed care rule, however, AHA expressed concern that certain policies may jeopardize states’ access to critical financial resources, especially CMS’ proposal to further restrict state sources of Medicaid financing and use hospitals to enforce compliance with CMS’s policy positions through new attestation requirements. AHA also encouraged CMS to adopt the average commercial rate as the upper payment for state-directed payments to hospitals, opposing any more restrictive upper payment approaches.  
 
AHA applauded CMS’ proposals to increase transparency in provider payment rates, expand stakeholder and beneficiary engagement, and improve access to home and community-based services in the FFS delivery system. Among specific concerns, AHA said it supports requiring states to evaluate and disclose how rates for certain critical services compare to Medicare FFS rates, but cautioned against assuming that Medicare FFS rates are adequate. “Indeed, Medicare underpayments of providers in 2020 totaled more than $75 billion. Instead, this analysis should be viewed as one piece of information as policymakers and stakeholders evaluate the impact of provider payment on beneficiary access to care.”   
 
Comments on both rules are due to CMS by July 3.