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.
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 · FinanceCalifornia Safety-Net Transformation Playbook Offers Model for Medicaid System Integration
Sellers Dorsey has published a strategic guide based on California's approach to integrating health and social services within its Medicaid safety-net system, aimed at improving outcomes for underserved populations. The playbook provides actionable frameworks for safety-net leaders to implement similar transformation strategies in their own Medicaid programs. This is particularly relevant as states increasingly look to California's innovations—including CalAIM and whole-person care models—as templates for managed care delivery system reform.
Managed CareAcademic Medical Centers Face Medicaid Revenue Risk from Policy Changes and Care Setting Shifts
This analysis examines how federal policy changes under the new administration may affect academic medical centers, which serve as major safety-net providers heavily reliant on Medicaid reimbursement. The piece addresses pressure to shift care from inpatient to ambulatory settings and regulatory changes that could strain AMCs' high fixed-cost structures, with particular implications for institutions serving underserved Medicaid populations. While the focus is on NIH funding and broader healthcare policy, the operational and financial pressures described have direct relevance to how AMCs manage their Medicaid managed care contracts and safety-net obligations.
How Generic Drug Manufacturers Face Medicaid Inflation Penalties Without Actually Raising Prices
This white paper examines how the Medicaid Drug Rebate Program's inflation penalty can trigger rebate obligations for generic manufacturers even when they haven't increased prices beyond inflation, due to purchasing pattern shifts, seasonal fluctuations, or commodity market dynamics. The analysis details five scenarios where AMP increases occur mechanically rather than through deliberate price hikes, creating financial pressure on generics manufacturers operating on thin margins. For MCO pharmacy programs and state Medicaid finance teams, this explains important dynamics affecting generic drug availability and rebate calculations.
Pharmacy · Managed Care · Finance340B Program Cost States $2 Billion in Foregone Medicaid Rebates in 2023, Analysis Finds
When 340B covered entities shift hospital outpatient drug claims from Medicaid into the 340B program, state Medicaid programs lose access to manufacturer rebates—totaling an estimated $2 billion in 2023 alone. The analysis highlights how rapid 340B growth, particularly among rural referral centers and disproportionate share hospitals, creates budget pressure for state Medicaid programs while patients may not receive direct cost-sharing relief. This matters for MCO compliance and finance teams navigating drug pricing arrangements and state directors managing pharmacy budgets under constrained fiscal conditions.
Pharmacy · Finance · Managed CareProposed 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 CareHealth 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 CareMontana 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 · FinanceTrump 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 HealthFederal Vaccine Advisory Committee Delays Could Impact State Medicaid Coverage Decisions
The Trump administration's temporary communications pause has postponed key vaccine advisory committee meetings that typically inform coverage policies across federal and state health programs. The piece examines how delays in vaccine recommendations from CDC and HHS committees could create downstream challenges for public health implementation, though it does not specifically address Medicaid managed care operations or state program implications. The analysis focuses primarily on federal vaccine policy infrastructure and advisory processes rather than payer-specific concerns.
Health Plans Face Strategic Choices on Enterprise Data Integration by 2030
Avalere and Tenasol argue that health plans currently operate fragmented data systems that create technical debt and compliance risks while missing opportunities for quality improvement. The analysis projects that plans will need enterprise-level data strategies integrating expanded sources—including social determinants of health data and electronic medical records—with emerging technologies to drive operational efficiency. While the piece addresses all health plans generically, Medicaid managed care organizations face particular pressure to integrate SDOH data and demonstrate quality outcomes under state contracts.
Managed CareSafety 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 CareWhite 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 HealthCMS 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 · FinanceHow 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 · FinanceIRA Drug Price Negotiation Expands to 15 More Products, Including High-Spend Diabetes and Behavioral Health Drugs
CMS has selected 15 additional Part D drugs for Medicare price negotiation under the Inflation Reduction Act, representing $41 billion in Part D spending and affecting 5.3 million beneficiaries. The list includes high-cost medications for diabetes, behavioral health conditions, and cancer that are also commonly covered in Medicaid managed care formularies. While the negotiation applies to Medicare, the pricing pressure and manufacturer strategies could influence Medicaid rebate structures and drug access in managed care plans that cover dual-eligible populations.
PharmacyIRS 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.
PharmacyDesigning Bundled Payment Models for Musculoskeletal Conditions: Key Features and Implementation Considerations
This white paper examines how health plans and provider organizations can structure bundled payment arrangements for musculoskeletal conditions like knee osteoarthritis, moving away from fee-for-service models. While the analysis applies broadly to value-based payment design across payers, the concepts are directly relevant to Medicaid managed care organizations exploring episode-based payment with orthopedic providers. The framework covers which organizations should enter bundled arrangements, model types, and why orthopedic episodes offer predictable cost and outcome patterns suitable for bundling.
Managed Care