Medicaid Monitor
Policy Intelligence
Medicaid Monitor
Policy Intelligence
Updated 12:07 PM MT
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Federal Policy·September 23, 2026

NAMD Submits Comments on Proposed Health Care-Related Tax Hold Harmless Rule

The National Association of Medicaid Directors submitted comments on September 21 responding to a CMS notice of proposed rulemaking that would amend the indirect hold harmless threshold for health care-related taxes. Health care-related taxes are a key financing mechanism states use to draw down federal Medicaid matching funds, and the hold harmless provisions limit the extent to which states can return tax revenue to providers. The proposed rule would modify the threshold that triggers federal hold harmless scrutiny, directly affecting state Medicaid financing flexibility and the permissible structure of provider tax arrangements.

Why it matters

Changes to hold harmless thresholds determine how much financing flexibility states have in structuring provider taxes that fund Medicaid expansion and services without risking federal disallowance.

Finance

Read the full article at medicaiddirectors.org →

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