May 22, 2018

Ms. Seema Verma
Centers for Medicare and Medicaid Services
Department of Health and Human Services
Room 445-G
Hubert H. Humphrey Building
200 Independence Avenue, S.W.
Washington, D.C. 20201

Submitted online to

Re: CMS–2406-P

Dear Administrator Verma,

The Association for Community Affiliated Plans (ACAP) greatly appreciates the opportunity to provide comments to the Centers for Medicare and Medicaid Services (CMS) in response to the Notice of Proposed Rulemaking (NPRM) with comment period on Methods for Assuring Access to Covered Medicaid Services – Exemptions for States With High Managed Care Penetration Rates and Rate Reduction Threshold published in the March 23, 2018 edition of the Federal Register (CMS–2406–P).

ACAP represents 61 member plans in 29 states serving more than 20 million Americans receiving coverage through Medicaid, CHIP, Medicare Advantage D-SNPs, and the Health Insurance Marketplaces. Nationally, ACAP plans serve roughly one-half of all Medicaid managed care enrollees. ACAP plans are committed 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.

Managed care has become the predominant delivery system in Medicaid. In this NPRM, CMS proposes an exception to the access monitoring requirements for those states that have a very high percentage of enrollees in managed care organizations (MCOs). By proposing this exception, CMS recognizes that access in managed care plans is monitored by the states and CMS via the requirements of the recently-updated managed care regulations. ACAP agrees with this assessment, and greatly appreciates efforts to incentivize states to further expand Medicaid managed care to additional populations, including high-utilizing enrollees.

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