NAHC Files Comments Opposing Medicaid Changes that Restrict Access to Care

Posted on Tuesday, May 29, 2018 7:23 PM

The National Association of Home Care and Hospice (NAHC) is strongly opposed to proposed changes regarding state analysis of access to care, public reporting and application of requirements for access monitoring review plan of Medicaid programs.

The U.S. Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) have proposed a few reforms in the requirements state Medicaid programs must follow in set payment rates in fee-for-service Medicaid benefits, in a March 23 Notice of Proposed Rulemaking (NPRM). Unfortunately, the proposed changes would significantly dilute the protections that existing rules provide relative to ensuring that payment rates are sufficient to secure access to care.

There are great risks to in home care given changes in minimum wage and overtime obligations under federal and state laws. These risks have been heightened in home care as providers compete for staff with institutional care providers who have the benefit of reasonable payments from commercial payers versus just those from government sources.

NAHC’s objections to the proposed rules and our reasoning are, as follows:

  1. CMS proposes to exempt states where at least 85 percent of Medicaid beneficiaries are enrolled in a Medicaid managed care plan. Entire populations of Medicaid beneficiaries could very well be put at risk if the CMS proposal comes to pass.
  2. CMS proposes to exempt rate reductions that are four percent or lower in one year or six percent over two years based on a classification of such rate reductions as “nominal,” but provides no evidence to substantiate its claims
  3. CMS should take steps to strengthen the reporting responsibilities of states and the process for protecting access to care in Medicaid rate setting
  4. The value of an effective rate evaluation system far outweighs any burden on the states.

NAHC wants CMS to withdraw its current proposal and work to strengthen the rate of setting protections that were started in 2016.

Source: NAHC

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