AHPA submitted comments on: CMS-2449-P; Medicaid Program; Medicaid Managed Care State Directed Payments and Medicaid Fee-for-Service Targeted Medicaid Practitioner Payments

Click here for the full comment letter. Below are some key takeaways.

• Limit the final rule to the payment restrictions expressly authorized by Congress:
  AHPA urges CMS to apply the Medicare-based payment restrictions only to the four service categories identified in statute: inpatient hospital services, outpatient hospital services, nursing facility services, and qualified practitioner services furnished at academic medical centers. It recommends preserving existing SDP methodologies and withdrawing the proposed targeted fee-for-service payment limit, which AHPA argues goes beyond Congress’s direction.
• Use an aggregate, administratively workable Medicare payment limit:
  AHPA opposes calculating compliance at the individual claim, service, or discharge level because Medicaid and Medicare use different codes, payment systems, and patient populations. It recommends allowing states to use the established Upper Payment Limit methodology and evaluating compliance at the provider or provider-class level, which would preserve fiscal oversight while accounting for differences in patient complexity, rural status, pediatric care, safety-net responsibilities, and regional access needs.
• Preserve uniform State Directed Payment increases and provider-class flexibility:
  AHPA recommends retaining uniform dollar and percentage increases because they are predictable, administratively efficient, and compatible with existing claims systems. Eliminating these arrangements would require states to redesign managed care contracts, fee schedules, actuarial certifications, and payment systems without a clearly demonstrated improvement in access, quality, or program integrity.
• Revise the grandfathered payment phase-down and protect existing arrangements:
  AHPA recommends calculating each annual reduction as 10 percent of the SDP’s remaining value for that rating year, rather than subtracting a fixed amount based on the original program value. It also urges CMS to preserve grandfathering for protected portions of mixed-service arrangements, allow necessary operational modifications without loss of grandfathered status, and provide at least one full rating period of transition after an SDP reaches the applicable payment ceiling.
• Provide complete guidance, sufficient implementation time, and protections for patient access:
  AHPA recommends that CMS publish full technical specifications for calculating Medicare-equivalent payment limits, allow public comment on the methodology, and provide states at least two full rating periods to implement changes. AHPA warns that overlapping federal requirements and payment reductions could increase uncompensated care and weaken access to obstetric, neonatal, pediatric, behavioral health, primary care, and rural services, particularly in states with low Medicaid reimbursement or large uninsured populations.