Medicaid Monitor
Policy Intelligence
Medicaid Monitor
Policy Intelligence
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Analysis & Perspectives

Commentary and analysis from outside consulting and policy firms — not part of Medicaid Monitor's independently scored news coverage. Each piece links back to the firm's original publication.

All FirmsManatt HealthAvalereMillimanGuidehouseSellers Dorsey
Avalere·10 months ago

Independent Pharmacies Face Growing Financial Pressure from Declining Medicaid Reimbursement

Independent pharmacies are struggling with financial viability driven in part by declining reimbursement rates across government payers including Medicaid, alongside Medicare and commercial plans. The analysis examines how pharmacy closures are creating access deserts that disproportionately affect vulnerable populations, with pharmacies adapting through expanded services like home delivery and vaccination programs. For Medicaid MCOs, pharmacy network adequacy and access remain critical compliance considerations as independent pharmacies face consolidation pressure.

Pharmacy
Avalere·10 months ago

State AI Regulations Increasingly Target Health Plan Prior Authorization and Utilization Management

Twenty-nine states and DC have enacted laws regulating AI use in healthcare as of August 2025, with prior authorization restrictions being a primary focus that spans Medicaid, Medicare Advantage, and commercial plans. These laws often prohibit AI from serving as the sole basis for coverage denials or require licensed physicians to make final adverse determinations, directly affecting how managed care organizations structure their utilization management programs. The regulatory landscape continues to evolve with at least 10 states considering additional AI-related healthcare legislation.

Managed Care
Avalere·10 months ago

USPSTF Overhaul Threatens Evidence-Based Preventive Service Coverage Standards

Reported plans to dismiss all USPSTF members raise concerns about politicization of preventive care recommendations that underpin coverage requirements under the ACA and Medicaid. Medical societies warn that disrupting the Task Force's evidence-based process could destabilize access to screenings and preventive services including cancer detection, HIV prevention, and maternal mental health interventions. Since USPSTF recommendations trigger mandatory coverage requirements for Medicaid managed care plans, changes to the Task Force's composition and methodology could reshape preventive care obligations and plan benefits.

Maternal
Avalere·11 months ago

Planned USPSTF Membership Overhaul Could Reshape Preventive Care Coverage Requirements for Health Plans

The administration's reported plan to dismiss all USPSTF members and reconstitute the panel could fundamentally alter preventive care coverage mandates that apply to Medicaid managed care organizations. Because ACA requirements tie no-cost preventive service coverage to USPSTF 'A' and 'B' grade recommendations, changes to the Task Force's composition and methodology could affect MCO benefit design, coverage obligations, and access to services like cancer screenings and PrEP. The move mirrors recent changes to ACIP that have already influenced vaccine policy across public programs.

Managed Care
Avalere·11 months ago

Budget Reconciliation Bill Tightens Provider Tax Rules, Threatening State Medicaid Financing Models

The One Big Beautiful Bill Act (OBBBA) introduces new restrictions on state provider taxes, a critical financing mechanism used by all states except Alaska to draw down federal Medicaid matching funds. The changes will force states to restructure how they fund Medicaid programs, with direct consequences for MCO rate-setting, provider reimbursement levels, and benefit coverage. Medicaid managed care organizations should prepare for potential state budget pressures that could impact capitation rates and contract terms as states scramble to replace lost federal matching dollars.

Managed Care · Finance
Avalere·11 months ago

State Biosimilar Substitution Laws Present Operational Challenges for Medicaid Pharmacy Programs

Avalere's updated 50-state survey documents how biosimilar substitution statutes vary across jurisdictions in authorization requirements, notification protocols, and dispensing conditions. For Medicaid managed care plans operating across multiple states, these statutory differences create compliance complexity in pharmacy benefit management, formulary design, and provider education. The report provides a reference tool for MCO pharmacy teams navigating interchangeable biosimilar policies that directly affect prior authorization workflows and member access.

Pharmacy · Managed Care
Avalere·12 months ago

GLP-1 Coverage for Obesity Treatment Remains Limited in Medicaid Despite Growing Pipeline

Coverage of anti-obesity medications, particularly GLP-1 receptor agonists, varies significantly across payer types, with Medicaid programs showing particularly restrictive policies despite a growing pipeline of over 40 products and projected market growth to $150 billion by 2030. The analysis examines how differences between commercial, Medicare, and Medicaid coverage create access disparities, with implications for state Medicaid programs navigating budget pressures alongside federal policy efforts to expand access. Medicaid managed care plans face particular challenges balancing long-term value against immediate cost concerns as member uptake increases.

Pharmacy · Managed Care
Avalere·12 months ago

USPSTF Recommendations Drive Preventive Care Coverage Requirements for Medicaid and Commercial Plans

USPSTF's A and B grade recommendations mandate coverage without cost sharing under the ACA for both commercial and public insurers, including Medicaid programs. The piece outlines how diagnostics developers and biopharmaceutical companies can strategically engage with USPSTF through new topic nominations or existing topic reconsiderations to influence preventive care coverage policies. While focused primarily on the evidence generation and USPSTF engagement process, the coverage mandate implications extend directly to Medicaid managed care organizations' benefit design and compliance obligations.

Avalere·12 months ago

Medicaid Unwinding and New Federal Redetermination Rules Threaten Adult Vaccine Access

Avalere examines how the end of Medicaid continuous enrollment led to 10 million disenrollments in 12 months, creating vaccine access barriers despite IRA protections, with state-by-state variation complicating national assessment. The analysis warns that new federal requirements under the One Big Beautiful Bill Act—including six-month eligibility redeterminations and work requirements—will likely worsen coverage churn and vaccination gaps. MCOs and state programs face intensifying challenges in maintaining preventive care continuity as enrollment volatility increases under the new policy environment.

Managed Care · Finance
Avalere·12 months ago

Federal Diabetes Research Program Yields $50B in Savings, Including Through Medicaid

Avalere estimates that research funded by the Special Diabetes Program has generated over $50 billion in federal healthcare savings through technologies like continuous glucose monitors and automated insulin delivery systems used by Medicare, Medicaid, and VA beneficiaries. The analysis focuses on direct medical cost reductions from improved diabetes management and reduced complications, with Medicaid representing one of three major public payers benefiting from these innovations. The findings have implications for how states and MCOs assess value from diabetes management technologies and clinical interventions.

Managed Care · Finance
Avalere·12 months ago

CMS Releases 400+ New Diagnosis Codes for FY 2026, Effective October 1

The Centers for Medicare & Medicaid Services and CDC have announced over 400 new ICD-10-CM diagnostic codes taking effect October 1, 2025, including codes for diabetes remission, multiple sclerosis progression, and various other conditions. These coding changes will affect claims processing, documentation requirements, and reimbursement methodologies for Medicaid managed care plans that rely on encounter data and risk adjustment. MCOs will need to update systems, train providers, and adjust coding workflows ahead of the October implementation date.

Managed Care · Finance
Avalere·12 months ago

ACIP Reconstitution May Reshape Vaccine Coverage Requirements for Medicaid Plans

The Advisory Committee on Immunization Practices was reconstituted with new members appointed by HHS Secretary Kennedy, signaling potential shifts in vaccine policy that could affect coverage mandates. Since ACIP recommendations trigger first-dollar coverage requirements across insurance programs including Medicaid, changes in the committee's direction could impact formulary requirements, preventive care mandates, and cost structures for Medicaid managed care plans. The piece examines how the committee's new composition may influence immunization schedules that directly affect MCO coverage obligations.

Avalere·12 months ago

Proposed AHRQ Budget Cuts Could Disrupt Medicaid Preventive Care Coverage Requirements

The Trump administration's proposed elimination of AHRQ's independent structure and $129 million budget cut threatens the USPSTF's ability to produce evidence-based preventive care recommendations. Because Medicaid managed care plans are required to cover USPSTF Grade A and B services without cost-sharing under the ACA, disruption to this process could create coverage uncertainty and compliance challenges for MCOs. The reorganization raises concerns about the independence and capacity of the evidence review process that drives mandatory preventive benefit design across commercial and public insurance.

Managed Care
Avalere·12 months ago

Trump Administration Pivots Behavioral Health Policy Away from Integration Toward Cost Control

The administration is shifting away from behavioral health integration and parity enforcement through changes at CMMI, potential weakening of mental health parity requirements, and proposed cuts to SAMHSA and CDC. These policy changes could significantly affect how Medicaid managed care plans structure behavioral health benefits, enforce parity, and participate in value-based models. The proposed FY 2026 budget cuts to SAMHSA ($1.1B reduction) and consideration of dissolving the agency altogether would directly impact state Medicaid behavioral health infrastructure and MCO programming.

Behavioral Health · Managed Care
Avalere·13 months ago

Medicare Drug Price Negotiation Changes Could Affect Medicaid Best Price Calculations

CMS released draft guidance for the 2028 cycle of Medicare drug price negotiations under the Inflation Reduction Act, expanding eligibility to include Part B drugs for the first time and proposing a single maximum fair price across Part B and Part D. While focused on Medicare policy, these negotiated prices have downstream implications for Medicaid managed care organizations through potential impacts on best price calculations and supplemental rebate agreements. The guidance also refines manufacturer exclusion criteria and seeks comment on how to evaluate therapeutic alternatives.

Pharmacy
Avalere·13 months ago

Literature Review Examines PBM Functions and Value Across Payer Types, Including Managed Medicaid

Avalere's white paper synthesizes published evidence on PBM roles across the healthcare system, including their administration of prescription benefits for managed Medicaid plans alongside commercial, employer, and Medicare Part D populations. The review examines PBM impact on costs, access, and clinical outcomes, finding evidence of adherence improvements and cost savings through rebate negotiations, while acknowledging heightened regulatory scrutiny from federal and state policymakers. For Medicaid MCO pharmacy directors and compliance teams, the paper provides context on PBM value propositions and evolving oversight landscape relevant to their vendor relationships and state contract requirements.

Pharmacy · Managed Care
Avalere·13 months ago

Opioid Use Disorder Costs $163K Per Case Annually to Payers and Government; Medication-Assisted Treatment Shows Net Savings

Avalere's national and state-level modeling quantifies the economic burden of opioid use disorder at nearly $1 trillion annually, with state and local government costs ranging from $137 to $524 per capita depending on geography. The analysis demonstrates that medication-assisted treatments—including methadone, buprenorphine formulations, and behavioral therapy—generate significant per-case cost savings, a finding directly relevant to Medicaid MCO benefit design, utilization management policies, and state pharmacy carve-in/carve-out decisions. With Medicaid covering a disproportionate share of individuals with substance use disorders, these cost-offset calculations inform managed care contracting, quality incentives, and state budget planning.

Behavioral Health · Managed Care · Pharmacy
Avalere·13 months ago

GLP-1 Market Analysis Includes Managed Medicaid Claims Data on Utilization Patterns

Avalere analyzed pharmacy claims across payer types including Managed Medicaid to assess on-label and off-label use of GLP-1 and GIP/GLP-1 receptor agonists for diabetes and weight management. The piece examines product differentiation strategies for manufacturers and notes that USP Drug Classification limitations affect coverage decisions in non-Part D plans. While focused primarily on manufacturer strategy and market dynamics, the analysis incorporates Medicaid managed care data and touches on formulary implications relevant to MCO pharmacy benefit management.

Pharmacy · Managed Care
Avalere·14 months ago

Proposed Medicaid Funding Reforms Could Cut Federal Children's Healthcare Spending by Up to $114 Billion Over Decade

Avalere modeling of three Congressional funding reform scenarios—per capita caps, expansion FMAP reductions, and removal of the 50% FMAP floor—projects total federal Medicaid cuts of $436-779 billion over ten years, with children's services losing between $57-114 billion. The analysis breaks down state-by-state impacts across different reform approaches, showing per capita caps would affect all states uniformly while FMAP changes would create highly variable impacts depending on expansion status. These projections provide MCOs and state Medicaid directors critical baseline data for understanding how federal funding restructuring could affect managed care capitation rates and children's service adequacy.

CHIP · Finance · Managed Care
Avalere·14 months ago

Federal Push to Mandate Medicaid Work Requirements Could Force MCO Eligibility and Enrollment Changes

With Congress seeking Medicaid savings through budget reconciliation, mandatory work requirements across states are gaining momentum as a cost-cutting measure. The analysis reviews how past state implementations in Arkansas and Georgia led to coverage loss and administrative complexity, with key design variables including which populations face requirements, exemption processes, and reporting burdens. For MCOs, renewed work requirements would require significant changes to eligibility verification systems, member outreach, and retention strategies while potentially shrinking enrollment.

Managed Care · Finance
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