Members of the Medicaid and CHIP Payment and Access Commission met last week in Washington, D.C.
The following is MACPAC’s own summary of the meeting:
MACPAC’s September 2026 meeting began with a discussion around community engagement (CE) requirements in Medicaid. The 2025 Budget Reconciliation Act established CE requirements and delegates to the Secretary the authority to set certain standards and procedures that the Centers for Medicare & Medicaid Services (CMS) addressed in the interim final rule with comment (IFC), issued on June 1, 2026. Staff summarized key IFC provisions, including individuals subject to CE, exceptions and exclusions from CE, state verification requirements, and beneficiary outreach requirements, as well as additional CMS resources. This session outlined the Commission’s framework for monitoring CE implementation. The Commission has indicated a strong interest in the CE policy and will monitor implementation activities.
Next, the Commission heard a panel discuss aspects of the IFC and newly published resources from CMS, how these resources are helpful to states, and areas where states need further guidance and clarification. Additionally, they discussed how states are preparing for implementation and other overlapping policy changes, including the new six-month redetermination requirement.
Panelists included:
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- Jack Rollins, Director of Federal Policy, National Association of Medicaid Directors
- Lora Saunders, Associate Principal, Health Management Associates
Staff then presented a summary of two proposed CMS rules to implement statutory limits on state directed payments (SDPs) and health care-related taxes (provider taxes) pursuant to the 2025 Budget Reconciliation Act. The proposed SDP rule implements the Medicare-based payment limit applicable to new SDPs. In addition, it extends the Medicare-based payment limits to all SDPs and certain targeted Medicaid fee-for-service practitioner payments. The provider tax proposed rule revises the indirect hold harmless threshold. It would also sunset the second prong of the hold harmless determination, often referred to as the 75/75 test, and creates a new permissible class of taxable providers for health insurers.
Following this, staff presented an update to the inpatient hospital index to reflect updated data and managed care spending. In 2017, MACPAC published an issue brief that presented an inpatient hospital payment index comparing Medicaid inpatient hospital fee-for-service payment across states and to Medicare. In this session, the analysis focused on a comparison of inpatient hospital payment levels across states and relative to the national average. MACPAC plans to present a comparison of Medicaid inpatient hospital payment to Medicare at a subsequent meeting.
Next, MACPAC continued its work to examine access to medications for opioid use disorder (MOUD) in Medicaid. This work explores whether utilization management strategies allow states and managed care plans to control costs and prevent misuse while maintaining appropriate and timely access to MOUD. Specifically, MACPAC focused on three utilization management strategies commonly applied to MOUD: prior authorization, daily dosage limits, and refill thresholds.
To end the day, staff presented work to examine how states use general and specialty managed care plans to serve children and youth in foster care including services offered, oversight, and data collection. During this session, staff reviewed key background information about children in foster care, summarized federal Medicaid managed care policies and requirements, and presented findings from a state policy scan of managed care contract language related to children and youth in foster care.
On Friday, the meeting began with a discussion around ensuring health and welfare in self-directed home- and community-based services (HCBS). In recent years, the Commission has explored self-directed HCBS as a delivery model for beneficiaries who receive long-term services and supports in their homes and communities. When offering HCBS, including self-directed HCBS, states must ensure beneficiary health and welfare per federal regulations. These federal policies balance beneficiary safety and dignity.
MACPAC reviewed the federal framework for beneficiary health and welfare in Medicaid HCBS, identified state approaches to ensuring health and welfare built upon this framework, and highlighted findings across states that are consistent with findings from the first phase of this work. Specifically, stakeholders consistently cited duplicative roles and responsibilities, as well as a lack of clarity in information and assistance supports, as barriers to ensuring beneficiary health and welfare. MACPAC staff presented a policy option for the Commission’s consideration to address challenges with information and assistance supports.
To conclude the meeting, MACPAC continued its examination of Medicaid coverage of assistive technology (AT) for adults using HCBS. MACPAC’s work includes identifying the statutory and regulatory framework that governs how states cover AT and assessing whether there are barriers to coverage of and access to AT that federal Medicaid policy could address. In April, MACPAC presented findings from a policy scan and literature review. In this session, MACPAC presented our findings from data analysis and stakeholder interviews. The data analysis focused on AT and specialized medical equipment and supplies, personal emergency response systems, home accessibility adaptions and vehicle modifications, and electronic/remote monitoring.
During the commission’s deliberations, MACPAC’s staff made the following presentations to the commissioners:
- Community Engagement Requirements in Medicaid: Interim Final Rule and Monitoring Framework
- Panel on Community Engagement Requirements: Key Interim Final Rule Provisions
- State Directed Payment and Provider Tax Proposed Rule
- Inpatient Hospital Payment Index: Comparison Across States
- Utilization Management for Medications for Opioid Use Disorder (MOUD) in Medicaid
- Children and Youth in Foster Care Enrolled in Medicaid Managed Care
- Ensuring Health and Welfare in Self-Directed Home- and Community-Based Services: Findings and Policy Option
- Medicaid Coverage of Assistive Technology for Adults: Data Analysis and Stakeholder Interviews
MACPAC is a non-partisan legislative branch agency that provides policy and data analysis and makes recommendations to Congress, the Secretary of the U.S. Department of Health and Human Services, and the states on a wide variety of issues affecting Medicaid and the State Children’s Health Insurance Program. Its deliberations are highly influential among policymakers and are especially important for community safety-net hospitals because those hospitals care for larger numbers and higher proportions of Medicaid and CHIP patients than the typical American hospital.
Find MACPAC’s web site here.

