VNAA Submits Comments to CMS on Medicaid Managed Care Regulation
Tuesday, July 28, 2015
by: Molly Smith, VP of Policy and Innovation

Section: Public Policy and Advocacy

Yesterday, CMS submitted comments to CMS on the Medicaid managed care proposed rule. In summary, VNAA commended CMS’ efforts to update these regulations and better incorporate issues related to long term services and supports (LTSS). VNAA provided recommendations on how to strengthen the proposal to protect beneficiaries’ access to home-based care. Specifically, VNAA:

  1. Advocated for CMS to prioritize coordinated care delivered in the home;
  2. Indicated support for provisions of the rule that would:
    • Address network adequacy, actuarial soundness and reinvestment in services (MLR) with the goal of increasing beneficiary access to services;
    • Require high quality and value from providers as well as increase the role of coordinated care for Medicaid; and
    • Require MCOs to adhere to Medicaid’s unique protections, including a guaranteed benefit of medically necessary services such as home care and hospice and freedom of choice among MCOs and providers.
  3. Underscored that Medicaid beneficiaries are different than enrollees in other insurance products and face more negative social and economic determinants of health and states must acknowledge these challenges and appropriately set quality measures and risk adjust to reflect these differences; and
  4. Encouraged the alignment of Medicaid with other federal and commercial insurance programs, in terms of policies, rules and quality reporting measures.

You can read VNAA’s full set of comments here.

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