AHA Statement on Medicaid Managed Care Access, Finance and Quality Rule

Ashley Thompson
Senior Vice President, Public Policy Analysis and Development
American Hospital Association

April 22, 2024

The AHA appreciates that CMS acknowledges the critical role hospitals play in state Medicaid financing and the importance of supplemental payments to sustain beneficiary access to care in light of low Medicaid base payment rates, including rates paid through managed care organizations. In particular, we applaud CMS’ recognition that hospitals treat all patients the same — regardless of coverage — by formally adopting the average commercial rate as the upper payment limit as advocated by the AHA. Codifying this provision ensures that hospitals have appropriate resources to serve Medicaid patients and strengthen America’s safety-net. The AHA also appreciates CMS’ efforts to streamline the approval of certain existing arrangements, which will cut down on bureaucracy and burden and allow hospitals to focus on their patients. 

Additionally, we thank CMS for listening to our concerns by delaying enforcement of the attestation provision as the various courts evaluate this issue. Though we remain concerned that the policy could result in financing restrictions that could have consequences for patient coverage and access, we appreciate the agency is preventing any confusion and unnecessary burden that could result from implementing the policy before these legal processes finish. 

Finally, the AHA applauds CMS’ efforts to strengthen network adequacy requirements and oversight. The finalized provisions represent common sense approaches to ensuring Medicaid beneficiaries enrolled in a managed care health plan can access the services they need. We look forward to continuing to work with CMS, states, and other stakeholders as they seek to implement new network adequacy standards.