Request for Extension of Comment Period for the Medicaid Managed Care Notice of Proposed Rulemaking

The Association for Community Affiliated Plans (ACAP) was pleased to see the Centers for Medicare and Medicaid Services (CMS) release an overhaul of Medicaid managed care regulations earlier this summer and appreciates the opportunity to offer our comments. Given the length and breadth of the regulations and ACAP’s desire to provide useful, thorough feedback, we urge CMS to extent the comment period for at least 30 days beyond the original July 27 deadline.

ACAP is an association of 59 not-for-profit and community-based Safety Net Health Plans (SNHPs) located in 24 states. Our member plans provide coverage to approximately 15 million individuals enrolled in Medicaid, the Children’s Health Insurance Program (CHIP) and Medicare Special Needs Plans for dually-eligible individuals. Nationally, ACAP plans serve roughly one-third of all Medicaid managed care enrollees.

The Medicaid managed care regulations will have a widespread impact on Safety Net Health Plans and the rest of the industry. ACAP, like many other stakeholders, has spent recent weeks thoroughly examining the regulations. We have hosted a series of phone calls and webinars about the regulations to educate our member plans about the contents of the regulations, generate discussion and solicit comments and feedback to get an on-the-ground perspective. Extending the comment period deadline for at least 30 days would allow ACAP to provide more meaningful, thorough comments that will be more useful to CMS as it crafts its final rule.

Issuing a notice to extend the comment period would not be without precedent. In 2011, when CMS was soliciting feedback on two draft rules about implementing exchanges and establishing standards related to reinsurance, risk adjustment, and risk corridors, the agency extended the comment period from September 28, 2011 to October 31, 2011.1 The additional month was invaluable to ACAP and commenters. CMS has issued several other comment deadline extensions in recent years as well.

The new proposed Medicaid Managed Care regulations are historic, and it is vital that CMS receives  meaningful feedback from stakeholder groups. In order to ensure that happens, ACAP respectfully urges CMS to extend the submission deadline until at least Wednesday, August 26. Thank you for your consideration.

If you have any additional questions or comments, please do not hesitate to contact Jenny Babcock (202-204-7518 or

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