ACAP Recommendations for Amendments to Medicaid Managed Care Final Regulations

Seema Verma
Centers for Medicare and Medicaid Services
200 Independence Avenue SW
Washington, DC 20201

Sent electronically

RE: ACAP Recommendations for Amendments to Medicaid Managed Care Final Regulations

Dear Administrator Verma,

In March 2017, CMS issued a letter to Governors promising a “full review of managed care regulations in order to prioritize beneficiary outcomes and state priorities.” The Association for Community Affiliated Plans (ACAP) wishes to take advantage of your review to provide you with our perspectives on the “Medicaid and Children’s Health Insurance Program (CHIP) Programs; Medicaid Managed Care, CHIP Delivered in Managed Care, Medicaid and CHIP Comprehensive Quality Strategies, and Revisions Related to Third Party Liability.” This final rule was published May 6, 2016 in the Federal Register. ACAP’s member plans have now operated under this rule for nearly two years, and have had time to consider its implications.

ACAP is an association of 61 nonprofit and community-based Safety Net Health Plans. Our member plans, located in 29 states, provide coverage to more than 20 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP), Medicare Special Needs Plans for dually-eligible individuals, and Qualified Health Plans (QHPs) in the health insurance Marketplaces. Nationally, Safety Net health Plans serve almost half of all Medicaid managed care enrollees. ACAP plans are members of their communities, partnering with states to improve the health and well-being of their members who rely upon the Medicaid and CHIP programs. Given that the primary line of business for ACAP Safety Net Health Plans is Medicaid, these regulations and any future amendments to them have substantial impact on our principal area of focus, investment, and expertise. We appreciate CMS’ intent to focus on quality, accessibility, and choices for Medicaid enrollees, and we continue to look forward to working with you and your staff to improve their health outcomes. We offer our thoughts regarding how management of Medicaid can be improved at the state and federal levels, and we applaud your efforts to align Medicaid with other major health care coverage such as the individual market. Thank you for your attention to our feedback.

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