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AAMC Responds to CMS RFI on Medicaid and CHIP Access

April 22, 2022

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CONTACTS
Mary Mullaney, Director, Hospital Payment Policies
For Media Inquiries

The AAMC submitted comments on April 18 in response to the Centers for Medicare & Medicaid Services (CMS) Request for Information (RFI) on Access to Coverage and Care in Medicaid and the Children’s Health Insurance Program (CHIP). The letter focused on coverage, access, and provider payment.

In the letter, the AAMC encouraged the CMS to utilize electronic communications to reach Medicaid beneficiaries to request and receive necessary information when making eligibility determinations and providing information assistance with enrollment into Marketplace plans when applicable. The comments also recommended the agency to promote states’ use of continuous coverage policies to decrease churn (temporary loss of coverage when individuals are disenrolled and then re-enrolled within a short period of time) and to work with states and communities to identify ways to proactively engage with trusted community partners to help meet Medicaid beneficiaries needs.

The letter addressed the need for “minimum national access standards for both Medicaid fee-for-service (FFS) and Managed Care Organizations (MCOs) to improve access for enrollees in both programs,” noting that “[t]hese standards should encompass access to all providers, including specialty and sub-specialty providers.” The letter also encouraged the CMS to “consider aligning Medicaid MCO network adequacy standards with the standards that govern plans in the federal Marketplace and Medicare Advantage,” stating that “those standards are designed to operate nationwide with sufficient flexibility to account for geographic differences, and so can appropriately be carried into the Medicaid program.”

Finally, the AAMC called on the CMS to “holistically evaluate the impact of Medicaid payment rates on access,” to include more frequent monitoring of “payment rates for both MCOs and FFS to determine if they are sufficient.” The letter noted that low reimbursement rates can limit Medicaid beneficiaries’ access to needed medical care.

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