ACAP Proposal: Include Medicaid Revenues in Disbursement of CARES Act Support to Providers

Jeff Van Ness, (202) 204-7515;


WASHINGTON—Today, the Association for Community Affiliated Plans (ACAP) issued a proposal for the U.S. Department of Health and Human Services to provide immediate relief to Medicaid providers by using funding from the Coronavirus Aid, Relief, and Economic Security (CARES) and Paycheck Protection Program and Health Care Enhancement Acts to provide the equivalent of one month of Medicaid revenue to providers who participate in the program.

To date, relief payments to Medicaid providers under the CARES Act have been insufficient to meet the escalating needs of safety net providers. The first set of payments, totaling $30 billion, relied on providers’ Medicare fee-for-service revenues. A recently-announced second set of payments totaling $20 billion is based on total revenue, but also excludes providers not participating in Medicare and underfunds providers who focus on serving patients through Medicaid.

ACAP’s proposal would allocate the equivalent of one month’s worth of Medicaid revenue, or about $47 billion, to providers who serve Medicaid patients.

“With the surge in unemployment, up to 23 million people might enroll in Medicaid over the next year,” said ACAP CEO Margaret A. Murray. “It’s in everyone’s interest to keep our Medicaid providers solvent, and to have a strong network that is ready for this surge in enrollment when it comes.”

Provider support would be calculated from payments arising from Medicaid managed care and fee-for-service programs, as well as supplemental programs such as Disproportionate Share Hospital payments. A table developed by The Menges Group provides calculations by state and by provider types (see below).

While state governments could calculate Medicaid fee-for-service payments by provider, health plans would be instrumental in calculating how much was spent by providers participating in managed-care networks – and either playing a role in disbursing the funds, or providing the information to state or Federal government agencies to aid in the disbursement of funds.

“In its efforts to get providers critical aid quickly, HHS used the data it had at hand – largely Medicare fee-for-service data – to calculate the first round of payments,” added Murray. “But their aid thus far has disadvantaged providers who primarily work in managed care delivery systems, and has left out entirely providers that don’t participate in Medicare. We can provide insight into the 45% of Medicaid funds that are capitated, and stand ready to help HHS get out crucial aid quickly and equitably.”

The proposal is available in full here. For more information, visit

TABLE: Total Allocation of Provider Funds: Medicaid FFS, DSH/GME/Supplemental, and MCO Providers Combined

For further analysis, see here.

About ACAP
ACAP represents 75 Safety Net Health Plans, which provide health coverage to more than 20 million people. Safety Net Health Plans serve their members through Medicaid, Medicare, the Children’s Health Insurance Program (CHIP), the Marketplace and other health programs. For more information, visit

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