New proposed rule seeks to standardize access to benefits across delivery systems and programs
Medicaid is the largest payor of long-term services and supports (LTSS) and the largest payor of services to treat substance use disorders (SUD) and pays for 40 percent of births in the United States. As such, millions rely on Medicaid for the vital care and services they need every single day, for LTSS, SUD, pregnancy, and many other health-related issues.
Still, access to quality care for many remains hard to come by due in part to inconsistent eligibility and care regulations across delivery systems and/or coverage authorities, including varying state agencies and managed care organizations (MCOs).
“With a program as large and complex as Medicaid, access regulations need to be multi-factorial to promote consistent access to health care for all beneficiaries across all types of care delivery systems in accordance with statutory requirements,” according to the U.S. Centers for Medicare & Medicaid Services (CMS).
In their continued efforts to increase access to care, CMS has proposed a new rule – “Medicaid Program; Ensuring Access to Medicaid Services” – which promises to further break down the barriers preventing individuals from benefiting from Medicaid coverage. Ultimately, with this new rule, CMS hopes to increase access to care by:
- Increasing transparency and accountability for organizations providing home- and community-based services (HCBS).
- Promoting beneficiary engagement in Medicaid programs.
- Standardizing data and monitoring waiver programs.
Based on feedback CMS has received from states and care organizations and more generally through a Spring of 2022 RFI process, there is a desire among the Medicaid community to standardize payment regulations and compliance across all Medicaid programs. There is a real interest in access to benefits to be as similar as possible across delivery systems and programs, no matter what state or delivery method.
The deadline to submit comments for the proposed rule is July 3, 2023. Several organizations, including ADvancing States, the National Association of State Directors of Developmental Disabilities Services (NASDDDS), the National Association of Medicaid Directors (NAMD), the National Association of State Head Injury Administrators (NASHIA) and the National Association of State Mental Health Program Directors (NASMHPD), submitted a letter to CMS requesting an extension of the comment deadline. Given that the timing of the proposed rule’s release was simultaneous with the resumption of Medicaid disenrollments, interested parties do not have adequate time to review the rule, the organizations argued.
“The scope and complexity of CMS’s policy ideas would require significant time to analyze and respond to in normal times,” the letter stated. “We do not find ourselves in normal times.”
While the organizations sought to have the deadline extended, they also expressed support for the CMS initiative.
“Our associations appreciate CMS’s goals with these regulations. Strengthening access to Medicaid and CHIP covered services and improving the quality of those services within fee-for-service and managed care delivery systems is a shared aim of the federal government, the states, and the territories,” the letter stated.
Promoting Barrier-Free Delivery of Care for All
Congress added Section 1915(c) to the Social Security Act in 1993, creating the Medicaid HCBS waiver program. Millions have benefited from this program in the last three decades, and the popularity of HCBS continues to increase as more and more people seek to age in place. This new regulation includes many provisions to improve the program and extend access and safeguard those in the program.
At FEI, we are committed to supporting the waiver programs that allow vulnerable populations – including the aging and disabled – to live and thrive in their communities. Our comprehensive case management solutions support the barrier-free delivery of health and human services to those that need them most, and we work with our state partners to configure our IT implementations to meet their unique program needs. We support continued efforts by CMS to improve HCBS and ensure high quality care for those that need it most.
