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AAMC Submits Comments on Medicaid and CHIP Managed Care Proposed Rule

July 24, 2015 —The AAMC July 23 submitted comments  on the Centers for Medicare and Medicaid Services (CMS) proposed rule on the Medicaid and Children’s Health Insurance Program (CHIP) Programs, Medicaid Managed Care, CHIP Delivered in Managed Care, Medicaid and CHIP Comprehensive Quality Strategies, and Revisions Related to Third Party Liability. In the rule, CMS aimed to improve alignment between Medicaid and CHIP managed care rules and practices with those of other health insurance providers.

The AAMC’s comments focus on network adequacy standards, setting sound capitation rates, graduate medical education (GME), direct payment prohibition, quality of care, and program integrity. The association made specific recommendations for CMS, including the following: 

  • Require states to establish a process to address inadequate wait times for specialties and subspecialties;
  • Be more specific in addressing the health needs of Medicaid populations by ensuring a thoroughly inclusive network of providers;
  • Establish a transparent  process  for patients and stakeholders to raise network adequacy grievances; and
  • Clarify that states may set minimum payment rates for providers within a class that meet a certain criterion.

The AAMC also raised concerns with CMS’ proposal to expand the “direct pay prohibition.” The prohibition currently forbids additional payments for services covered under managed care contracts, with some exceptions. CMS would expand the prohibition to stop states from directing plan expenditures under contracts. The final rule will be released later this year.


Ivy Baer, J.D., M.P.H.
Senior Director and Regulatory Counsel
Telephone: 202-828-0499


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806