ADvancing States submitted yesterday comments on CMS’ notice of proposed rulemaking (2390-P) to revamp Federal requirements for Medicaid managed care programs. Medicaid has significantly evolved and improved since these regulations were adopted in 2002, when managed care plans primarily served pregnant women, children and their parents. In the past thirteen years, the use of managed care delivery systems has exploded, so that almost 60% of all Medicaid beneficiaries are enrolled in one or more health plans.  For the Medicaid consumers that our members serve through HCBS waivers and state plans – older adults and persons with physical disabilities, managed care is an increasingly common delivery system. In 2004, only eight states had managed long-term services and supports programs; as of 2015, there are twenty-one MLTSS programs, with more than ten states in the planning phases. It is therefore critical that any new framework for Medicaid managed care thoughtfully address the nuances of delivering HCBS services to a diverse population.
 
ADvancing States’s comments were centered around managed long-term services and supports and how they are appropriately incorporated and addressed in a number of areas, including consumer protections, quality, state oversight and contract/payment requirements. We applaud CMS’ efforts to broaden the scope and depth of the current regulations, and look forward to modifications in the final rule.
 
View the letter here.
 
CONTACT: For further information, please contact Camille Dobson, Deputy Executive Director at 202-898-2578.