In a letter
dated July 23, the National Association of Medicaid Directors (NAMD) commended CMS for its plans to propose updates to existing Medicaid managed care regulations, guidance, and business processes, and urged ongoing consultation with state Medicaid directors about concepts under consideration, in order to "minimize the chance of unintended consequences." The letter includes the first of several planned recommendations regarding managed care, which focuses on rate-setting development and oversight of actuarial soundness. NAMD identifies four key goals relating to rate-setting regulations review that it urges CMS to work with states to achieve:
1. Make the processes more efficient with regard to the amount and scope of CMS involvement.
2. Make the process more reflective of the maturity of state programs and approaches to rate setting.
3. Make the process more predictable with regard to the timing of approvals and effective dates.
4. Establish processes and policies that support state innovation in rate setting methodologies and care delivery.
Among its recommendations, the letter asks CMS to use a two-tiered process for reviewing Medicaid managed care rate-setting innovations. Level 1 would include limited involvement by the CMS central office, used for states that have "achieved a demonstrated level of experience with Medicaid managed care." Level 2 review would occur when the submission includes "a new population or method" or when the state "is in the initial phases of establishing a Medicaid managed care program."
The Republican Governors Association (RGA) also sent a letter last week to Senators Mitch McConnell (R-KY), Lamar Alexander (R-TN) and John Barrasso (R-WY), advocating a similar approach to that in the NAMD letter. That letter urged that states be allowed to implement changes to their Medicaid programs based on existing program agreements, rather than going through the sometimes lengthy process of getting CMS approval. It further urged that governors should have the flexibility to design innovative, patient-centered programs, and be treated as equal partners in implementing Medicaid reforms.