KFF Finds Medicaid Rate Transparency Rules Cover Narrow Service Slice
In a new brief, KFF describes Medicaid fee-for-service payment transparency requirements that took effect in July 2026 under the Ensuring Access to Medicaid Services final rule, including comparative rate analyses against Medicare, published fee schedules, and disclosure of home care hourly rates. Using T-MSIS data, KFF finds that the 68 billing codes CMS specified for the Medicaid-to-Medicare comparative rate analysis account for only 2% of noninstitutional FFS spending and 5% of noninstitutional FFS claims. KFF notes that comparing rates across states remains difficult due to variation in reporting practices, populations, and geographic areas, and that the value of the comparative data will depend on each state's delivery system and how closely MCO rates track FFS rates. Separate managed care payment transparency requirements apply to rating periods beginning on or after July 9, 2026, with analyses due in Network Adequacy and Access Assurances Reports submitted starting January 1, 2028.