By CMS is proposing to relax rules requiring states to submit and update Medicaid access monitoring review plans, which would largely leave states in charge of ensuring adequate Medicaid beneficiary access to care.
“Rather than micromanaging State programs through complex federal mandates, CMS is easing the administrative burden on States while focusing on holding them accountable for delivering high-quality, accessible care to beneficiaries,” said CMS Administrator Seema Verma.
The original rule passed in November 2015, which CMS seeks to replace, required states to submit an access monitoring review plan (AMRP). AMRPs provide data on statewide access to services under fee-for-service contracts and these plans must be sent to CMS for review every three years. The plans report on primary care services, physician specialist services, behavioral health services, pre- and post-natal obstetric services, and home health services.
CMS passed the original rule in order to ensure that the states’ Medicaid reimbursement rates are enough to attract an appropriate number of providers, ensuring adequate Medicare beneficiary access to care.
However, states found the requirements of the 2015 rule overbearing and outdated, CMS explained in the proposed rule. The process involves an extensive amount of staff to collect and analyze the data.
Furthermore, the data, which focuses on fee-for-service contracts, is inaccurate when put in the context of Medicaid’s shift to managed care.
Through the National Association of Medicaid Directors, the states requested to collaborate with CMS on new, more effective standards.
In response, CMS developed a proposed rule in February 2018 which allowed for exemptions. The proposal received little support from state leaders who felt that the proposed thresholds for exemption were not clearly backed by data.
Given this reaction, CMS proposed the new rule that allows states to submit evidence of access to care with their state plan amendments (SPAs).
The agency suggests that states should update their access information when submitting an SPA. CMS also promised to work with experts from state and federal stakeholders to develop a “comprehensive and outcomes-driven” method to monitor Medicaid beneficiary access to care.
CMS believes that since 2015, the federal government’s ability to gather data through the Transformed Medicaid Statistical Information System has greatly improved and the agency’s awareness of how best to monitor and evaluate access using this information has likewise increased, making elimination of the AMRPs possible.
Additionally, CMS has been collaborating with an unidentified vendor to determine the best way to standardize access measurements.
CMS expressed the desire to publish “subregulatory guidance” in tandem with the new ruling, if it is finalized. While the proposal eliminates the need for AMRPs, it maintains the need for states to submit evidence that their Medicaid reimbursement rates are sufficient to obtain and retain enough providers to offer equal access to all beneficiaries. CMS’s guidance would guide state Medicaid directors regarding data collection and analysis methods required for an SPA.
The agency estimated that the new data collection requirements could reduce administrative burden by $23,969.40 per monitoring plan for a total of $1,222,439 combined savings for the nation’s Medicaid program.
“Although this proposed rule would remove the regulatory process requirements for states to develop and update an AMRP and to submit an access analysis when proposing to reduce or restructure provider payment rates in circumstances that could result in diminished access, states are still obligated by the statute to ensure Medicaid payment rates are sufficient to enlist enough providers to assure that beneficiary access to covered care and services are available…particularly when reducing or restructuring Medicaid payment rates through SPAs,” the proposed rule concludes.