This month’s edition of Health Policy News highlights recent developments related to the Medicaid program. At the Federal level, we provide a summary of the recently published Proposed Rule on Medicaid and CHIP Managed Care, as well as an overview of a recent State Medicaid Director Letter regarding opportunities to increase access to behavioral health care services. For states, we outline three important factors to consider when seeking to implement community engagement-related Medicaid eligibility requirements (also known as work requirements).
CMS Proposes Changes to the Regulations Governing Medicaid and CHIP Managed Care
On November 14, 2018, the Centers for Medicare and Medicaid Services (CMS) published a proposed rule making changes to the Medicaid and Children’s Health Insurance Program (CHIP) Managed Care regulations. CMS had notified states in March of 2017 that it was thoroughly reviewing the Medicaid and CHIP Managed Care regulations, which were last overhauled in April 2016. The newly-proposed changes seek to provide more flexibility within the regulations and promote transparency, efficiency, and innovation.
Comments on the regulations are due on January 14, 2019. In addition to general feedback, CMS is seeking input regarding specific questions outlined throughout the document.
Among the most significant changes are:
- Reintroducing capitation rate ranges;
- Allowing for multi-year approval of directed expenditures for value-based purchasing arrangements and other delivery system reform initiatives;
- Allowing for transitional pass-through payments for supplemental payments even if populations or services are newly transitioning to managed care;
- Making the network adequacy standards less stringent;
- Providing states discretion in setting the maximum time period beneficiaries have to request Medicaid fair hearings.
For a detailed overview of the substantive changes proposed, click here.
CMS Issues Guidance on Medicaid Behavioral Health Delivery System Reform
On November 13, 2018, CMS released a letter to State Medicaid directors outlining a wide range of opportunities for states to design innovative delivery systems for adults and children with serious mental health conditions.
The CMS letter offers guidance on strategies to improve care for these individuals using Medicaid state plan provisions, managed care contracts, and health homes. In addition to opportunities to receive Federal Medicaid matching funds for health care services, states may also be able to include other key activities as administration costs. The letter also details a new initiative to expand coverage of needed services via Section 1115 Medicaid Waivers. The new waiver initiative focuses on expanding coverage for services delivered during stays in Institutions for Mental Diseases (IMDs).
For more information about the letter and opportunities available to states, click here.
Early Lessons Learned from Implementing Community Engagement Requirements
With five states having been granted approval to condition a person’s eligibility to receive Medicaid on their participation in community engagement activities (also referred to as “work requirements”), implementation underway in one of those states, and similar approval being sought by another 11 states, it is an opportune time to consider early lessons learned. This has particularly come to the forefront given that Arkansas has removed 12,277 individuals from the state’s Medicaid program in less than six months of implementation. In fact, 91.6 percent of those individuals who were required to report on community engagement activities in September 2018 failed to do so, causing concern among many health policy experts about the ramifications of implementing community engagement requirements.
Earlier this month, the Medicaid and CHIP Payment and Access Commission (MACPAC), sent a letter to the Secretary of the U.S. Department of Health and Human Services articulating its concerns and suggested actions related to dis-enrollment of individuals from Arkansas Medicaid. Arkansas’ experiences provide other states with the opportunity to observe its implementation and develop their own best practices. In particular, states hoping to implement such requirements should give careful consideration to the needs of the population being faced with responding to new requirements, technological changes, member communications, and reporting that this change entails. For more detailed considerations, click here.