If the Office of Management and Budget’s website is to be believed, CMS will release the long-awaited Medicaid managed care rule in the coming weeks (our conversations with senior CMS officials indicated a similar timeline.) The federal regulations governing Medicaid managed care have not been updated since 2002 and much has changed in the program since then, most notably managed care enrollment numbers: between 2002 and 2015 the percentage of managed care enrollees has grown from roughly 50% to nearly 80%. The impact of these new regulations will thus be felt by a far larger segment of the Medicaid population, then they more than 10 years ago when last updated.
What will be included in the regulations? We don’t know for sure, but there has been a great deal of speculation. Our friends at the Kaiser Commission on Medicaid and the Uninsured have put together a great brief on issues to watch for: click here to see that brief.
Here are some of the highlights from our perspective:
- Does the IMD exclusion apply to Medicaid managed care plans?
- Will CMS require greater detail from MCOs in order to ease the ability of comparing plans for enrollment purposes?
- Will beneficiary appeals rights’ be strengthened? Must MCOs provide continuing services during the appeal process?
- Will CMS implement a set of standardized quality measures for Medicaid MCOs?
- How will the rule impact managed long-term services and supports?
These are big issues to watch for. As the National Journal recently wrote, this rule could be “epic.”