The AAMC Jan. 4 submitted a comment letter on the Centers for Medicare and Medicaid Services (CMS) final rule, Medicaid Program: Methods for Assuring Access to Covered Medicaid Services. The final rule comes four years after the issuance of CMS’ proposed rule.
The finalized rule includes a new requirement that state reviews be at least once every three years, rather than the current five years.
The letter states AAMC’s support for the shorter timeframe but expressed concern that CMS’ effort to reduce potential burden on states could weaken protections for beneficiaries. Only a select set of services would be included in the triennial review including: primary care, physician specialist, behavioral health, and pre- and post-natal obstetric care (including labor and delivery), and home health. The AAMC encourages CMS to expand the list of core services to include hospital inpatient services.
The letter continues, “It is not only crucial inpatient services that hospitals provide to Medicaid beneficiaries. CMS should ensure that every state’s Medicaid population has access to the different types of care provided by hospitals, including highly specialized surgeries and procedures, burn and trauma care, psychiatric care, and substance abuse treatment.” The AAMC encourages CMS to “acknowledge that Medicaid beneficiaries should have adequate access to all subspecialties.”
Finally, the rule requires states to have mechanisms in place to obtain ongoing beneficiary feedback and requires ongoing provider feedback. The AAMC supports this modification and encourages CMS to require states to document all responses to ensure accountability.
Comments for the Request for Information (RFI) regarding additional feedback on core measures and threshold requirements were also due on Jan. 4, 2016.