This NAMD letter responds to a supplemental proposed rule from the Substance Abuse and Mental Health Services Administration on the privacy requirements for substance use disorder (SUD) information (42 CFR Part 2). The letter underscores that separate privacy requirements for SUD information continue to prevent high quality, coordinated care for beneficiaries. It also makes recommendations […]

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NAMD submitted comments to CMS on the agency’s proposed rule that would impact eligibility and fair hearing processes in Medicaid. In general, the Association’s letter expresses concern that the rule does not recognize the variation in process and procedure that is appropriate among states in the fair hearing process.  Read full letter.  

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NAMD Submits Comments on Future of HCBS

On January 9, NAMD provided comments in response to a CMS Request for Information seeking stakeholder input on a variety of questions addressing the provision of Medicaid home and community-based services (HCBS). In the comments, NAMD calls for CMS to be mindful of states’ unique role in HCBS program administration and the continually evolving HCBS […]

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NAMD submitted comments on a CMS proposed rule impacting the use of pass-through payments in Medicaid managed care programs. We express concern with CMS’s pass-through payment policy overall and specifically comment on the proposed effective date of the rule’s changes. Read the letter.

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NAMD Comments on Final MACRA Regulation

NAMD submitted comments on the Final Regulation with Comment implementing the Medicare Access and CHIP Reauthorization Act (MACRA). NAMD’s letter addresses unique Medicaid considerations in the multi-payer component of MACRA’s Advanced APM program. Read full letter.

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This letter outlines Medicaid Directors’ ongoing concerns with CMS’s interpretation of the Medicaid managed care rule’s Institutions for Mental Diseases (IMD) provisions, and makes recommendations to enhance flexibility and streamline implementation of these provisions. Read full letter.  

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