CMS Finalizes Two Regulations Significantly Impacting the Financial Administration of Medicaid and Medicaid Managed Care

On April 22, 2024, the Centers for Medicare and Medicaid Services issued two important Medicaid final rules for public inspection: (1) Ensuring Access to Medicaid Services Final Rule (CMS-2442-F) and (2) Medicaid and Children’s Health Insurance Program Managed Care Access, Finance, and Quality Final Rule (CMS-2439-F). We will provide updates to the posts we issued last year when these rules were proposed to identify and analyze the impact of these new rule.

In the past, we have heard that the redlines we prepared were helpful to others as they understand the content of new rulemaking. Here are links to:

• CMS’ fact sheet on the Ensuring Access to Medicaid Services Final Rule

• A redline between the current section 447.203 and the Ensuring Access to Medicaid Services Final Rule

• A redline between the proposed Ensuring Access to Medicaid Services section 447.203 and the Final Rule

• CMS’ fact sheet on the Medicaid and Children’s Health Insurance Program Managed Care Access, Finance, and Quality Final Rule

• A redline between the current Part 438 and the Medicaid and Children’s Health Insurance Program Managed Care Access, Finance, and Quality Final Rule

• A redline between the proposed Medicaid and Children’s Health Insurance Program Managed Care Access, Finance, and Quality Part 438 and the final rule

We anticipate issuing new, updated posts on the areas we posted about last year: (1) changes to state directed payments; (2) ratesetting and oversight; (3) network adequacy and access; and (4) in lieu of services. Please stay tuned for these updates.

For more information on the final Medicaid regulations, please submit an inquiry.