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Medicaid Transportation Services in Jeopardy?

The White House has proposed removing non-emergency transportation from the list of mandatory Medicaid benefits.

The proposed FY 2020 budget released last week explained that

Statute allows, but does not require, States to provide non-emergency medical transportation (NEMT).  Instead, these services were made mandatory Medicaid benefits by regulation.  Further, a Government Accountability Office study found Medicaid NEMT spending totaled $1.5 billion in 2013, and NEMT programs face multiple challenges, including difficulties in obtaining costs and maintaining program integrity.  To address these issues, this proposal would update regulations to clarify the NEMT benefit is strictly optional.

Medical transportation has long been viewed as vital means for helping Medicaid patients keep doctors’ appointments and recover from their illnesses and injuries and for overcoming some social determinants of health.  Loss of this tool would be harmful for private safety-net hospitals and the patients and communities they serve.  NASH will closely monitor the progress of this proposal.

Protections Overlooked as Medicaid Reforms are Implemented

In its eagerness to help states introduce changes in their Medicaid programs and reduce administrative burdens, the Centers for Medicare & Medicaid Services is ignoring regulatory requirements designed to understand and measure the impact of those changes on beneficiaries.

According to an analysis by the Los Angeles Times, many states seeking to implement Medicaid work requirements have not projected how many of their beneficiaries would be affected by those requirements nor have they projected how many beneficiaries who are removed from the Medicaid rolls will gain employment after losing their Medicaid benefits.  Both projections are required under Medicaid regulations adopted in 2012, which call for states to assess the anticipated impact of proposed policy changes when seeking federal permission to implement such changes.

Similarly, many states have not proposed commissioning independent assessments to determine the impact of the Medicaid changes they have implemented with CMS’s approval – another requirement under 2012 regulations.

When pressed to explain its failure to enforce these regulations, according to the Times, CMS said only that regulations “…do not require that states provide precise numerical estimates of coverage impacts…” and that it is developing strategies for states to evaluate the impact of new work requirements.  The Medicaid and CHIP Payment and Access Commission wrote to Health and Human Services Secretary Alex Azar about Medicaid disenrollment in states with new work requirements but after three months, Secretary Azar has not responded to MACPAC’s inquiry.

Medicaid disenrollment is a particular challenge for private safety-net hospitals because they serve more Medicaid patients than most hospitals and patients who lose their Medicaid coverage and need hospital care typically cannot afford to pay for that care, leaving such hospitals with growing amounts of uncompensated care.

Learn more about the process for reviewing state requests to implement Medicaid work requirements and CMS’s enforcement of regulations governing its approval of such requirements in the Los Angeles Times article “In rush to revamp Medicaid, Trump officials bend rules that protect patients.”

 

Government More Effective Than Private Sector at Controlling Health Care Costs

For the past dozen years, Medicare and Medicaid have done a better job of controlling rising health care costs than private insurers.

Since 2016, according to a new report from the Urban Institute, private insurers’ costs per enrolled member have risen an average of 4.4 percent a year.  By contrast, Medicare costs have risen an average of 2.4 percent per enrollee and Medicaid costs have risen just 1.6 percent per enrollee.

The primary driver of Medicare cost increases has been prescription drug spending.  For Medicaid the primary driver has been physician services and administrative costs.  For private insurers, the main reason for increasing costs has been spending for hospital care.

Learn more about the differences in cost containment in these different sectors and the implications of those differences in the Urban Institute report “Slow Growth in Medicare and Medicaid Spending Per Enrollee Has Implications for Policy Debates.”

New Report Looks at Medicaid and Social Determinants of Health

A new report outlines how state Medicaid programs can improve the health of Medicaid beneficiaries through a more concerted approach to addressing social determinants of health.

The report, from the Institute for Medicaid Innovation, focuses on how state Medicaid programs, through alternative payment models and especially through managed care organizations, have implemented new programs designed to address social determinants of health such as inadequate social supports and housing, food insecurity, lack of transportation, and others.  It also highlights federal regulations that facilitate the implementation of new ways to address social determinants of health and presents brief case studies in which states, state Medicaid programs, and Medicaid managed care organizations tackle social determinants of health.

Such approaches are especially relevant to private safety-net hospitals because they care for so many more Medicaid patients than the typical community hospital.

Learn more from the Institute for Medicaid Innovation report “Innovation and Opportunities to Address Social Determinants of Health in Medicaid Managed Care.”

Could Medicaid Buy-In Push Aside Medicare for All?

Officials in ten states are giving consideration, in one form or another, to permitting uninsured low-income residents to buy into their Medicaid programs.

So while Washington considers the possibility of Medicare for all, the ten states – Nevada, New Mexico, California, Delaware, Oregon, Washington, Connecticut, Illinois, Minnesota, and Wisconsin – are tackling the many issues they must address if they intend to pursue such a ground-breaking option.  Among them:

  • Who would be eligible to participate?
  • What benefits would be offered?
  • Would health plans be available on Affordable Care Act health exchanges, and if so, would ACA subsidies be available to potential purchasers?
  • How would cost-sharing, such as premiums, co-pays, and deductibles, be addressed?
  • In the absence of federal matching funds, how would the states pay for their share of Medicaid benefits purchased by those not eligible for Medicaid?
  • Would such as effort be approved by the federal government?

To the extent that Medicaid buy-in would turn uninsured patients into insured patients, Medicaid buy-in would be beneficial for private safety-net hospitals.

Learn more about what the states are considering and the potential obstacles they face in the Stateline article “Medicaid ‘Buy-In’ Could Be a New Health Care Option for the Uninsured.”

 

HHS Gives States New Options for Medicaid-Covered Behavioral Health Treatment

The U.S. Department of Health and Human Services has informed state Medicaid programs that it is giving them new opportunities to pay for hospitalization to care for recipients with behavioral health problems.

For years Medicaid has greatly limited the ability of state Medicaid programs to pay for inpatient care for many behavioral health problems – a limit commonly known as the IMD (institution of mental disease) exclusion.  Earlier this year the Centers for Medicare & Medicaid Services eased this long-time limit, announcing that it would make it easier for states to secure waivers from it.  CMS has announced in a formal guidance letter to state Medicaid directors that it is extending this policy, according to a CMS news release, which explains that the agency offers

…both existing and new opportunities for states to design innovative delivery systems for adults with serious mental illness (SMI) and children with serious emotional disturbance (SED).  The letter includes a new opportunity for states to receive authority to pay for short-term residential treatment services in an institution for mental disease (IMD) for these patients.  CMS believes these opportunities offer states the flexibility to make significant improvements on access to quality behavioral health care.

Under this new approach, states are invited to develop new delivery systems for serving patients with behavioral problems, and especially substance abuse disorders, that make greater use of inpatient behavioral health services and to receive federal Medicaid matching funds for pay for this care – something that has been greatly limited in the past.  In offering this opportunity, CMS notes that a number of states that have already obtained waivers from the IMD exclusion since its easing of the limit on such waivers earlier this year and are already showing encouraging results in their battle against opioid abuse.

Learn more about this new policy, its intentions, and how it will work in this CMS news release or go here to see the CMS guidance letter to state Medicaid directors.

CMS Proposes New Medicaid Managed Care Regulation

Just two years after a major overhaul of Medicaid managed care regulations, the Centers for Medicare & Medicaid Services is again proposing changes in how the federal government regulates the delivery of managed care services to Medicaid beneficiaries.

Under the newly proposed regulation, states would:

  • be free to implement more changes in their managed care programs without seeking federal permission;
  • have slightly more flexibility in how supplemental payments are made to hospitals through managed care plans and implement some such changes without federal approval;
  • be permitted to redefine what constitutes an adequate provider network for managed care plans; and
  • not be required to publicize beneficiary grievance and appeals processes as prominently as they currently do.

Overall, the proposed regulation appears to help managed care insurers a great deal, states a little, and hospitals barely at all.  It also could have serious implications for private safety-net hospitals, most of which are located in states that employ managed care in their Medicaid programs.

Stakeholders have until January 14 to submit formal comments about the proposal to CMS.

To learn more about the proposed Medicaid managed care regulation, go here to see CMS’s news release presenting the regulation, go here to see a more detailed CMS fact sheet, and go here to see the proposed regulation itself.

CMS Promises Enhanced Use of Medicaid Data to Improve Program Results

Centers for Medicare & Medicaid Services administrator Seema Verma intends to increase federal use of data reported by the states to improve the performance of state Medicaid programs.

In an article published on the CMS blog, Verma wrote that

Through strong data and systems, CMS and states can drive toward better health outcomes and improve program integrity, performance, and financial management in Medicaid and CHIP.

Verma pointed to two core sets of data she considers vital:  Medicaid and CHIP child and adult core sets, which are reported only voluntarily by states, and administrative data submitted through the relatively new Transformed-MIS system.  The latter, according to Verma.

…modernizes and enhances the way states submit operational data about beneficiaries, providers, claims and encounters.  It is the foundation of a national analytic data infrastructure to support programmatic and policy improvements and program integrity efforts and will help advance reporting on outcomes.  It also enhances the ability to identify potential fraud and improve program efficiency.

All states now use Transformed-MIS.

Learn more about how CMS uses data now and how it envisions using it in the future to improve the performance of state Medicaid programs in the CMS blog entry “CMS Promises Enhanced Use of Medicaid Data to Improve Program Results,” which can be found here.

CMS Unveils Medicaid “Scorecard”

The Centers for Medicare & Medicaid Services had introduced a new “Medicaid scorecard” that the agency says it hopes will “…increase public transparency about the programs’ administration and outcomes.”

The scorecard, now posted on the Medicaid web site, presents information and data from the federal government, and reported voluntarily by the states, in three areas:  state health system performance, state administrative accountability, and federal administrative accountability.

The scorecard currently offers information on selected health and program indicators.  Visitors can see comparative data between states and also extensive information about individual state Medicaid programs, including eligibility criteria, enrollment, quality performance, and key state documents such as state plan amendments, waivers, and managed care program overviews.  The site also presents individual state and comparative state performance based on a variety of metrics while also reporting on federal turnaround time on matters such as waiver requests and rate reviews.  CMS envisions the scorecard evolving from year to year by offering more and different information.

Go here to see a CMS fact sheet on the new Medicaid scorecard and go here to visit the scorecard’s home page.

ACOs Moving Into Medicaid

Accountable care organizations, one of the centerpieces of recent Medicare efforts to test new ways to deliver care more effectively and at less cost, are finding their way into state Medicaid programs as well.

Today, a dozen states employ Medicaid ACOs and another ten are planning to do so.

Learn more about Medicaid ACOs, and how one state (Minnesota), in particular, is using them, in this Kaiser Health News report.