Good Morning NAHC Members:
Our analysis of the Access Final rule is available online at: NAHC Analysis of the Medicaid Access Rule
A high-level summary includes:
The final rule maintains the requirement that 80% of Medicaid payments for three specific services be paid to direct care workers as compensation but provides some relief from the notice of proposed rulemaking. As discussed in detail in the analysis, the relief takes several forms:
- A later compliance date, extending the timeline from 4 years in the proposed rule to 6 years in the final rule;
- A modified calculation, which clarifies inclusion of certain expenses (such as worker compensation) in the 80%, expands the 80% definition to include nurse supervision, and excludes certain expenses, such as training, PPE, and mileage, from the calculation completely; and
- Options for "hardship exemptions" and an alternative threshold (ie: less than 80%) for small providers.
Other components of the rule were largely in-line with provisions from the proposed rule, and the majority were positive improvements to Medicaid HCBS, including:
- Increased transparency regarding state payment rates, including the most recent update to those rates;
- Stronger CMS oversight of state proposals to reduce reimbursement rates;
- Establishment of a mandatory HCBS quality measure set; and
- Enhanced health and welfare protections through the required incident management system;
Overall, while there are many positive provisions within the final rule as well as mitigations to make the payment adequacy provision less onerous, NAHC remains extremely concerned about the negative consequences of the pass-through policy. NAHC will host a webinar on Thursday, April 25th, to provide more detailed analysis and discussion of the final rule. Information on the webinar is available at: https://nahc.org/what-the-medicaid-access-rule-means-for-care-in-the-home/
| National Association for Home Care & Hospice |
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| NAHC Analysis of the Medicaid Access Rule |
| On April 22, 2024, the Centers for Medicare and Medicaid Services (CMS) released the final Medicaid Access Rule (CMS-2442-F). The regulation becomes "effective" on July 9, 2024, which is 60 days after... |
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Damon Terzaghi
Director of Medicaid Services
National Association for Home Care & Hospice
Washington DC
+1 (202) 547-7424
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