The AAMC submitted July 9 comments (PDF) in response to the Centers for Medicare & Medicaid Services (CMS) Preserving Medicaid Funding for Vulnerable Populations — Closing a Health Care-Related Tax Loophole Proposed Rule [refer to Washington Highlights, May 16]. The rule proposes to revise the Medicaid regulations related to the waiver of broad-based and uniform requirements for health care-related taxes. These requirements ensure health care-related taxes are generally redistributive.
Coinciding with the CMS’ proposed rule was the July 4 enactment of the One Big Beautiful Bill Act (OBBBA, P.L. 119-21), which included many significant changes to the Medicaid program, some of which overlap with the proposals contained in this rule [refer to Washington Highlights, July 3]. In light of these competing changes, the AAMC urged the agency to withdraw and reevaluate the proposals included in this rule. The association’s comments highlighted the impact limiting these Medicaid financing mechanisms will have on providers and on beneficiaries’ access to care. However, should the CMS decide to move forward with finalizing the proposals, the AAMC encouraged the agency to limit subjectivity in the waiver approval process and ensure Medicaid financing mechanisms are sufficient to support beneficiaries’ access to care. Comments also requested the agency implement a longer transition period of three years for all impacted states to ensure states can come into compliance with potential changes to minimize harm to state Medicaid programs.