Summary and Considerations on CMS’ RFI on ‘Access to Coverage and Care in Medicaid & CHIP’

The Medicare and Medicaid programs themselves are not old enough to qualify for Medicare coverage (quick history lesson: President Lyndon Johnson signed the Social Security Amendments into law on July 30, 1965, and the Medicaid program launched on January 1, 1966; note that CMS traces the origin of its programs back to President Theodore Roosevelt’s advocacy for social insurance).  Over the past half-century (and then some), both programs have incrementally adapted—and significantly evolved—to address changing health needs, and to align with each administration’s priorities.

Democratic and Republican administrations alike have implemented Medicaid reforms to support vulnerable populations and improve access to health care.  For example: the Reagan Administration expanded Medicaid waivers to give states greater flexibility to provide home- and community-based care; the Clinton Administration oversaw the passage of State Children’s Health Insurance Program (SCHIP) to provide health insurance to children whose families had incomes too high for Medicaid but could not afford private insurance; and the Bush Administration managed the transition of the coverage of pharmacy-dispensed drugs for dual eligible Medicare/Medicaid beneficiaries to the new Medicare Part D program.  Over a decade after the passage of the Patient Protection and Affordable Care Act (ACA), states have the option to expand Medicaid coverage to adults with incomes up to 133% of the Federal poverty level (FPL).

CMS under the current administration places a premium on improving health equity by expanding access to Medicaid coverage.  Today, we are going to discuss Medicaid’s request for information (RFI) on strategies for Medicaid to increase beneficiary access, particularly for behavioral health and home- and community-based care.

Further Details on CMS’ RFI

On February 17, CMS issued an RFI titled Access to Coverage and Care in Medicaid & CHIP (comments are due on April 18).  According to CMS, this RFI expands on the agency’s 2015 RFI, which itself shaped several policies.  With this latest RFI, CMS is requesting stakeholder input on health service delivery, methods, payment models, barriers to Medicaid and CHIP enrollment and access, and how to support access to behavioral health and home- and community-based services.  CMS will incorporate feedback from some responses into its standalone access rule, which is currently set for publication in October 2022 (according to the most recent regulatory agenda).

To collect responses for this RFI, CMS set up an online form (available here), rather than using a comment-letter submission process.  The RFI has five main objectives pertaining to Medicaid access issues, and each objective has four or five specific questions.

The RFI’s five objectives are:

  • Medicaid and CHIP reaches people who are eligible and who can benefit from such coverage.
  • Medicaid and CHIP beneficiaries experience consistent coverage.
  • Whether care is delivered through fee-for-service or managed care, Medicaid and CHIP beneficiaries have access to timely, high-quality, and appropriate care in all payment systems, and this care will be aligned with the beneficiary’s needs as a whole person.
  • CMS has data available to measure, monitor, and support improvement efforts related to access to services (i.e., potential access; realized access; and beneficiary experience with care across states, delivery systems, and populations).
  • Payment rates in Medicaid and CHIP are sufficient to enlist and retain enough providers so that services are accessible.

Commenters can respond to these specific questions directly, using the form (each question has a box to input text).  According to CMS, commenters can respond to individual questions as they see fit; there is no requirement to respond to every question in the form.

CMS leadership previously explained that each comment box could hold the equivalent of 20 pages (or 20,000 characters).  Commenters can also paste links to Google Docs (via embedded URL) or infographics in their responses.  Importantly, comments do not have to be submitted in one sitting; commenters can save their responses and submit the form later.  Interested parties should submit their comments by April 18.

Next Steps

As we noted above, CMS will incorporate feedback from certain responses into its standalone access rule later this year.  CMS leadership also explained that it plans to build responses into future rulemaking.  Additionally, CMS will release information about when it plans to make comments available for public viewing.

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