In a Sept. 11 letter(2 page PDF) to CMS Administrator Seema Verma, M.P.H., that was signed by AAFP Board Chair Michael Munger, M.D., of Overland Park, Kan., the Academy said it does not support CMS' proposed rescission of the Medicaid access rule because doing so "could jeopardize access to critical Medicaid coverage" for millions of Americans.
The AAFP appealed to CMS to withdraw the proposed rule.
In the rule,(www.govinfo.gov) published in the July 15 Federal Register, CMS noted its intention to ease some of the administrative burden that states currently face in trying to document whether Medicaid payments in fee-for-service systems are high enough to encourage physicians and other health care professionals to provide services to Medicaid beneficiaries.
The proposed rule outlines CMS' contention that by compelling states to collect specific information, the agency "excessively constrains state freedom to administer the program in the manner that is best for the state and the Medicaid beneficiaries in the state."
The AAFP noted its shared commitment to reducing administrative burden for states and clinicians, but argued that the proposed rule, as written, would likely negatively affect Americans in rural areas, as well as some of the country's most vulnerable patient populations that depend on Medicaid for health care services.
- In a recent letter to CMS, the AAFP advised the agency to withdraw a proposal that would rescind the Medicaid access rule.
- The AAFP said CMS' proposed rule could jeopardize critical access to care for millions of Medicaid beneficiaries.
- The letter said a better way to ensure access would be to raise Medicaid physician payment levels to at least Medicare rates.
The AAFP suggested that rather than rescind the Medicaid access rule, the agency should instead review data already reported by states. Doing so would help CMS better evaluate patient access to the Medicaid program.
The letter pointed out that states first submitted access monitoring review plan data in October 2016 and will do so again shortly -- by Oct. 1, 2019.
"The access monitoring requirements enacted under the 2015 rule were a positive first step to ensure beneficiaries can access needed services," said the AAFP.
The letter encouraged CMS to "build on this first step, review 2019 submissions and improve our understanding of access in the states before loosening the monitoring requirements."
Medicaid beneficiaries deserve access to high-quality care when they need it, and access to necessary services is particularly critical for patients with disabilities and those with chronic and complex health conditions, said the AAFP.
Treatment delays lead to poorer outcomes and unnecessary costs to the health care system, the letter added.
The AAFP noted its agreement with a stand taken by the Medicaid and CHIP Payment and Access Commission in a May 2018 letter(www.macpac.gov) that asked CMS to monitor rate reductions and to maintain a process for beneficiaries, physicians and other health care professionals to tell CMS about the implications of these reductions.
The AAFP also called on CMS to continue to seek public input on Medicaid payment rate changes to
- ensure transparency,
- incorporate broad stakeholder perspective and
- guard against unintended consequences.
The AAFP stated that it could support an "aligned strategy" to analyze Medicaid access across programs as long as CMS maintains the current structure until any new approach is finalized.
In closing, the AAFP pointed out that a better way to ensure that Medicaid beneficiaries can access health care would be for states and the federal government to prioritize efforts to raise Medicaid physician payment levels "to at least Medicare rates for services rendered by a primary care physician."
The letter noted that nationwide, Medicaid payment is anywhere from 33% to 66% of Medicare payment for primary care services.
"Lack of parity between these rates has historically created a demonstrable barrier to health care access for low-income, disabled and elderly Medicaid enrollees," said the AAFP.
Many physicians simply cannot afford to provide care to Medicaid patients because of low payment rates, the letter concluded.
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