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MACPAC Comment Letters

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MACPAC Comments on CMS Proposed Rule to Revise Health Care Tax Safe Harbor Threshold

The Medicaid and CHIP Payment and Access Commission (MACPAC) submitted comments to CMS on a proposed rule that would revise the indirect hold harmless threshold — the safe harbor — used to determine whether health care-related taxes impermissibly shift Medicaid costs to the federal government. The proposed rule changes how CMS evaluates whether provider tax arrangements violate federal Medicaid financing requirements. This affects state Medicaid financing strategies that rely on provider taxes to fund non-federal share of payments, a common mechanism used by states to draw down federal matching funds.

MACPAC

Federal Policy·36d ago

MACPAC Comments on Proposed Medicare Advantage Rule for Contract Year 2027

The Medicaid and CHIP Payment and Access Commission submitted comments to CMS on proposed Medicare Advantage policy and technical changes for contract year 2027. The letter focuses on dual eligible special needs plans (D-SNPs), which serve beneficiaries enrolled in both Medicare and Medicaid. MACPAC has prioritized D-SNPs given their widespread use and the coordination challenges between Medicare Advantage plans and state Medicaid programs. The comment letter addresses proposed changes affecting how these plans operate and coordinate care for dual eligibles.

MACPAC

Federal Policy·36d ago

MACPAC Submits Comment Letter on Medicaid Program Integrity to CMS

The Medicaid and CHIP Payment and Access Commission (MACPAC) submitted a comment letter to CMS in response to a request for information on combatting fraud, waste, and abuse in federal health care programs. MACPAC's letter addresses four areas: eliminating ineffective or redundant program integrity activities and requirements, promoting high-value program integrity activities, identifying barriers to program integrity, and providing evidence-based findings and recommendations. The comment letter reflects MACPAC's policy research and advisory role to Congress on Medicaid program integrity issues.

MACPAC

Federal Policy·36d ago

MACPAC Comments on Proposed Rule for Interoperability Standards and Drug Prior Authorization

The Medicaid and CHIP Payment and Access Commission submitted comments to HHS Secretary Robert F. Kennedy, Jr. on proposed rulemaking addressing interoperability standards and prior authorization requirements for prescription drugs. The proposed rule would implement new interoperability standards for payers, including state Medicaid programs and managed care plans. MACPAC's letter provides the Commission's assessment of the rule's provisions and their potential impact on Medicaid program operations, drug access, and administrative burden for states and plans.

MACPAC

Managed Care·36d ago

MACPAC Comments on CMS Proposed Rule for State Directed Payments and Targeted Practitioner Payments

The Medicaid and CHIP Payment and Access Commission submitted comments to CMS Administrator Dr. Mehmet Oz on a proposed rule governing state directed payments in managed care and targeted practitioner payments in fee-for-service. MACPAC supports CMS efforts to align Medicaid payments with statutory requirements for economy and efficiency. The comment letter addresses proposed changes to how states can direct managed care organizations to make specific payments to providers and how states structure targeted payments in FFS arrangements. The proposed rule affects state Medicaid agencies' flexibility to use payment strategies that support provider rates and access while meeting federal oversight requirements.

MACPAC