The AAMC submitted comments on June 27 to the Centers for Medicare & Medicaid Services (CMS) in response to the proposed rule “Medicaid Program: Medicaid and Children’s Health Insurance Program (CHIP) Managed Care Access, Finance, and Quality” focused on Medicaid managed care delivery systems. If finalized, the proposed rule would represent significant changes to federal Medicaid and CHIP regulations. The CMS incorporated a number of proposals, including those aimed at refining state directed payments (SDP), defining an academic medical center for the purposes of SDPs, and establishing appointment wait time standards to boost network adequacy standards.
In its comment letter, the AAMC asked the agency to ensure Medicaid payment rates are sufficient to make sure beneficiary access to care and supported the CMS’ proposal to continue to allow states to increase payment limits for Medicaid. Specifically, the AAMC requested that the agency finalize their proposal to use the average commercial rate (ACR) as the appropriate total payment rate limit for inpatient hospital services, outpatient hospital services, nursing facility services, and qualified practitioner services at academic medical centers. Additionally, the association suggested the CMS not finalize the proposed definition of an academic medical center and instead use the following definition: a facility that “includes a teaching hospital and is affiliated with a health professional school.” Lastly, the AAMC provided comments on the proposal to establish a new network adequacy standard that would include appointment wait time standards. The association recommended that the CMS consider aligning Medicaid Managed Care Organization (MCO) network adequacy standards with the standards that govern plans in the federal Marketplace and Medicare Advantage as well as institute national access standards for both the Medicaid fee-for-service model and MCOs to improve access for enrollees.