The Centers for Medicare & Medicaid Services (CMS) published a companion guide (PDF) for states on implementing fee-for-service (FFS) payment and access to care provisions of the Ensuring Access to Medicaid Services final rule [refer to Washington Highlights, April 26]. The guide focuses exclusively on Medicaid FFS provisions and does not apply to Medicaid managed care.
In the guide, the CMS provides instructions to states on complying with provisions of the ensuring access final rule, including payment rate transparency publication, payment rate disclosures for home and community-based services, comparative payment rate analysis, and state analysis of proposed rate Medicaid FFS rate reductions or restructuring. The guide also includes examples of documentation required for the payment rate transparency publication, the comparative payment rate analysis, and the payment rate disclosure requirements. States must begin to comply with these requirements beginning July 1, 2026, with the exception of the rate reduction and restricting analyses, which took effect on July 29.