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.

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Manatt Health·14 months ago

Telehealth and AI Positioned as Tools to Address Provider Shortages Affecting Access to Care

Manatt Health and MUSC outline how telehealth modalities like virtual nursing and eConsults, combined with AI-enabled automation, could extend workforce capacity amid severe provider shortages projected to worsen through 2037. The analysis identifies barriers to telehealth scale including limited reimbursement and insufficient evidence, challenges directly relevant to MCO network adequacy and access strategies. While not Medicaid-specific, the workforce crisis disproportionately affects Medicaid populations and the solutions discussed have clear implications for managed care operations and state policy decisions around telehealth coverage.

Managed Care
Manatt Health·14 months ago

Health Systems Can Quantify Financial Returns from Employed Primary Care Despite Operating Losses

Manatt Health presents a methodology for calculating the total value employed primary care practices generate for health systems through downstream revenue, reduced network leakage, quality bonuses, and acute care cost avoidance—even when practices show operating losses of $249,000 per physician. The analysis includes an illustrative case study of a 40-physician practice with 100,000 paneled lives including 15,000 Medicare Advantage members, demonstrating how primary care investment supports value-based care models. While the framework touches Medicaid managed care indirectly through its focus on Medicare Advantage and general managed care principles, the piece does not substantively address Medicaid-specific policy, MCO operations, or state program considerations.

Managed Care
Manatt Health·14 months ago

New Toolkit Helps States Model Financial Impact of Federal Medicaid Cuts Under Budget Reconciliation

Manatt Health released a state-by-state analysis tool estimating how proposed Congressional cuts—including reduced federal matching rates for expansion adults, elimination of the 50% FMAP floor, and per-capita caps—would affect Medicaid spending and enrollment through 2034. The toolkit models scenarios ranging from states ending expansion (resulting in a 32% national enrollment drop) to states backfilling lost federal funds (requiring $836 billion in new state spending). This resource gives state Medicaid directors and MCO executives concrete data to inform budget planning and advocacy as reconciliation proposals advance.

Managed Care · Finance
Manatt Health·15 months ago

Federal Education Restructuring Could Disrupt IDEA Funding and Coordination with Medicaid Programs for Children with Disabilities

The Trump administration's executive order to close the Department of Education raises questions about federal oversight of special education services for over 7.5 million children with intellectual and developmental disabilities, including enforcement of IDEA requirements and distribution of funding. The analysis highlights potential implications for Medicaid managed care organizations, as many early intervention programs coordinate closely with state Medicaid programs, and changes to federal education policy could affect how MCOs deliver coordinated care to children with disabilities. The restructuring could shift compliance responsibilities and funding mechanisms that currently support integrated service delivery between education and health systems.

CHIP · Managed Care
Manatt Health·15 months ago

States Target Private Equity Ownership in Health Care with New Corporate Practice Restrictions

California, Oregon, and Washington have introduced legislation tightening corporate practice of medicine prohibitions, which could force restructuring of private equity-backed management service organizations and physician practice arrangements. The bills would restrict MSO control over clinical decisions, impose stricter physician ownership requirements, and limit certain contractual arrangements between professional corporations and management companies. These changes could affect how Medicaid managed care plans contract with provider groups that rely on private equity backing or MSO structures, potentially impacting network adequacy and provider availability.

Manatt Health·15 months ago

California Standardizes Medically Supportive Food Services in Medi-Cal Managed Care Plans

California has evolved its approach to nutrition interventions within Medi-Cal managed care, moving from its 2022 launch of medically tailored meals as an optional "in lieu of services" Community Support to increasingly standardized offerings based on stakeholder feedback. The state's experience illustrates how managed care plans are implementing social drivers of health benefits that aim to prevent costly downstream medical care for members with diet-sensitive conditions. This progression reflects broader Medicaid policy trends as CMS has formalized the in lieu of services authority that California pioneered for addressing social determinants through managed care.

Managed Care
Manatt Health·16 months ago

New State Toolkit Addresses Private Equity and Financialization Risks in Health Care Delivery

Manatt releases guidance for state regulators on monitoring and controlling financial investment activity—including private equity acquisitions—across health care delivery systems, with emphasis on protecting quality, access, and costs. The toolkit documents over $1 trillion in PE health care transactions in the past decade and offers states strategies to strengthen transparency requirements, prevent market concentration, and enhance quality protections. For Medicaid managed care leaders, this is relevant because financialization of provider networks, specialty practices, and safety-net hospitals directly affects network adequacy, care quality, and rate negotiations with investor-owned entities.

Managed Care · Finance
Manatt Health·17 months ago

Proposed HIPAA Security Rule Updates Would Require Medicaid Plans to Increase IT Security Spending Within 240 Days

Federal regulators have proposed the first major updates to HIPAA security requirements since 2013, responding to a 1,000% increase in individuals affected by data breaches over five years. The proposed rule would impose more prescriptive compliance timelines and documentation requirements on all health plans and providers, including Medicaid MCOs, with most requirements taking effect within 240 days if finalized. While the rule's fate under the Trump administration remains uncertain, cybersecurity's bipartisan support may increase its survival chances compared to other late-Biden-era health regulations.

Managed Care
Manatt Health·17 months ago

Health Tech Startups Navigate Quality Measurement Programs to Demonstrate Value to MCO Customers

Manatt Health advises health technology companies to understand the mechanics of quality measurement and payment programs to realistically assess their impact on performance metrics. The guide targets startups selling to health plans and other risk-bearing entities where quality measure improvement represents a potential revenue driver or value proposition. While not Medicaid-specific, quality measurement programs like HEDIS are fundamental to Medicaid managed care operations and MCO contracting.

Managed Care
Manatt Health·17 months ago

Montana Medicaid Expansion Report Examines Program Performance Ahead of 2025 Legislative Reauthorization Decision

Manatt Health's annual assessment of Montana's Medicaid expansion program evaluates its impact on health outcomes, state budget, and the broader health care system as the legislature considers whether to reauthorize coverage for adults up to 133% FPL. The report, produced for the Montana Healthcare Foundation in partnership with the state's health department, analyzes claims data and economic indicators to inform policy decisions on a program covering eligible adults, children, pregnant women, and people with disabilities. With expansion authorization set to expire without legislative action, the findings provide critical context for state Medicaid directors and MCO executives operating in Montana's market.

Managed Care · Finance
Manatt Health·17 months ago

Trump Executive Order Directs HHS to End Federal Funding for Youth Gender-Affirming Care, Raising Medicaid Coverage Questions

A January 2025 executive order instructs federal agencies to cease support for gender-affirming care for individuals under 19, with HHS directed to potentially modify coverage rules and impose new grant conditions on providers. The directive carries direct implications for Medicaid managed care plans and state programs that currently cover such services, setting up potential conflicts between federal enforcement and state laws protecting transgender care access. MCOs may face new coverage restrictions or provider network compliance requirements as agencies work to implement the order within 60 days, though legal challenges are expected.

Managed Care · Behavioral Health
Manatt Health·17 months ago

Safety Net Providers Face Barriers to AI Adoption That Could Worsen Medicaid Access Disparities

Safety net hospitals and providers serving high Medicaid and uninsured populations lag behind other institutions in adopting AI and other emerging technologies due to funding constraints and lower reimbursement rates. Without targeted policy support and innovative financing mechanisms, this technology gap risks perpetuating health disparities for Medicaid beneficiaries with complex needs. The piece argues policymakers must prioritize funding strategies to help safety net institutions implement AI tools that could improve workforce management and care delivery for vulnerable populations.

Managed Care
Manatt Health·17 months ago

White Paper Calls for Medicaid EPSDT Coverage Clarification for Dyslexia Screening and Treatment

Manatt Health argues that dyslexia—affecting up to 20% of children—should be treated as a medical condition with screening, testing, and treatment covered by Medicaid and commercial insurance rather than relegated to educational services. The report specifically calls for CMS to clarify Medicaid EPSDT coverage obligations for dyslexia services and advocates for state coverage mandates, positioning early intervention as both clinically necessary and cost-effective given the estimated societal burden of untreated dyslexia. This directly implicates MCO benefit design, medical necessity criteria, and state contract requirements around pediatric developmental screenings.

Managed Care · Behavioral Health
Manatt Health·17 months ago

CMS Withdraws Healthy Adult Opportunity Waiver Authority for Capped Funding and Closed Formularies

CMS formally rescinded 2020 guidance that allowed states to cap federal Medicaid funding in exchange for greater flexibility, including closed drug formularies, arguing these Healthy Adult Opportunity waivers conflict with Medicaid's statutory objectives. Tennessee was the only state to implement such a waiver under TennCare III before voluntarily withdrawing the capped financing and closed formulary provisions following legal pressure. While the rescission strengthens legal arguments against similar waivers, it does not prevent the incoming Trump administration from reintroducing the policy, setting up potential renewed interest from states and legal challenges.

Managed Care · Pharmacy · Finance
Manatt Health·17 months ago

How Safety Net Hospitals Can Build Effective State Advocacy Strategies to Secure Medicaid Funding

Manatt outlines core advocacy tactics for safety net hospitals seeking state Medicaid funding, emphasizing the need to align proposals with state policy priorities like behavioral health and maternal health. Using New York as a case study, the piece describes how hospitals have successfully secured transformation grants and other state investments by framing requests around workforce development, emergency department redesign, and psychiatric programs. The guidance is directly relevant to Medicaid MCO partners and state officials who collaborate with safety net providers on access and delivery system improvements.

Managed Care · Behavioral Health · Maternal · Finance
Manatt Health·18 months ago

IRS Narrows Scope of IRA Drug Price Negotiation Excise Tax to Medicare-Only Sales

The IRS has proposed limiting the excise tax on manufacturers who refuse Medicare drug price negotiation to sales made only to Medicare beneficiaries, rather than all sales including Medicaid. This interpretation significantly reduces the potential tax exposure for drug manufacturers under the Inflation Reduction Act, which could have implications for drug pricing strategies across both Medicare and Medicaid programs. The proposed rule also excludes the tax amount itself from the calculation base, further minimizing manufacturer liability.

Pharmacy
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