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Comment Letter: Proposed Rule on Medicaid and CHIP Managed Care Access, Finance, and Quality

In a letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure, MACPAC commented on CMS’s proposed rule to improve access monitoring and oversight of managed care directed payments in Medicaid and the State Children’s Health Insurance Program (CHIP).

The proposed rule would change CMS’s approach to access monitoring in managed care by adding several new requirements for beneficiary surveys, minimum appointment wait times, and payment analyses.

Overall, the Commission supports CMS’s efforts to promote greater payment transparency and encourages CMS to align transparency requirements in fee for service (FFS) and managed care.

The proposed rule also includes a number of changes intended to improve the oversight of managed care directed payments, which have become a large and growing share of Medicaid payments. The Commission strongly supports the changes that are consistent with MACPAC’s recommendations in its June 2022 report to Congress.

The Commission also provides technical comments on other aspects of the proposed rule based on MACPAC’s prior analyses of managed care policies.