The National Alliance of Safety-Net Hospitals has submitted formal comments to the Centers for Medicare & Medicaid Services in response to CMS’s proposed changes in federal Medicaid managed care regulations.

NASH’s letter addressed three aspects of the proposed regulation:  payment rate ranges, directed Medicaid payments, and Medicaid pass-through payments.  The overall theme underlying NASH’s comments was that the proposed changes represent positive steps but could be taken further to provide additional flexibility for state Medicaid programs to take stronger steps to ensure the ability of private safety-net hospitals to serve their communities.

NASH expressed support for CMS’s restoration of the use of actuarial rate ranges in setting Medicaid managed care rates but urged CMS to make those rate ranges even broader or even eliminate them provided that negotiated rates still meet formal criteria for actuarial soundness.

NASH endorsed CMS’s expanded parameters for the use of Medicaid directed payments through managed care but encouraged CMS to expand those parameters even further than it has proposed.

And NASH called on CMS to restore the ability of states to use pass-through payments in Medicaid managed care programs, as they can do through Medicaid fee-for-service programs, so long as those payments remain actuarially sound.  In 2016 a new Medicaid managed care regulation called for the phase-out of such payments over a period of ten years but NASH asked CMS to suspend that phase-out.

Learn more about NASH’s perspective by reading NASH’s comment letter to CMS in response to the proposed Medicaid managed care regulation.