On July 3, NAMD submitted comments on CMS’s proposed access rule. Together, CMS’s proposed managed care and access rules seek to ensure that Medicaid members can access high-quality care when they need it, to strengthen home and community-based services, and to support Medicaid agencies in identifying and resolving access issues.
Medicaid Directors strongly support these overall goals. However, navigating the complexities of how to move our current system closer to these aims is challenging. In our comments, NAMD highlights implementation concerns, including the overall volume of provisions, the associated systems lift and costs, and reporting and evaluation burden. CMS should consider extended implementation timelines, flexibilities, and resources to address these challenges.
Our comments on the access rule also address CMS’s specific proposals, including changes to Medical Care Advisory Committees, new requirements for home and community-based services, and rate transparency provisions.
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