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AAMC Comments on Exemptions to Medicaid Equal Access Requirements

May 25, 2018

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PRESS CONTACTS
Mary Mullaney, Director, Hospital Payment Policies
Andrew Amari, Hospital Policy and Regulatory Specialist

The AAMC May 21 submitted a comment letter to the Centers for Medicare and Medicaid Services (CMS) in opposition to the agency’s proposal to create two exemptions for states from the Medicaid equal access requirements. The AAMC’s comment addresses significant concerns for fee-for-service Medicaid beneficiaries’ access to care.

The Medicaid equal access protections require states to submit an access monitoring review plan (AMRP) that analyzes the sufficiency of access to care for Medicaid fee-for-service (FFS) beneficiaries every three years. Specifically, the proposal would exempt states with managed care penetration rates above 85% from AMRP requirements, and states submitting plan amendments with nominal rate changes, defined as 4% over one state fiscal year (SFY) or 6% over two SFYs, would not be required to consider the AMRP when reducing rates. According to the AAMC letter, CMS’s proposed exemptions jeopardize access to care for the most vulnerable recipients of Medicaid assistance, such as disabled and dual-eligible beneficiaries, in order to reduce administrative burden for states. The AAMC recommended that CMS should not finalize either threshold.

The AAMC’s comments emphasize that CMS is responsible for protecting its Medicaid populations, and should err on the side of caution when issuing exemptions that may negatively impact equal access to care. The letter also adds that the proposed exemptions have arbitrary thresholds and remove the opportunity for beneficiary and provider input as it relates to equal access to care.

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