The NCMS joined with national and state physician organizations this week in offering comments and recommendations to the Centers for Medicare and Medicaid Services (CMS) about the proposed Rule, Methods for Assuring Access to Covered Medicare Services. In a letter to CMS Administrator Donald Berwick, MD, the organizations applauded CMS “for recognizing the need for states to measure beneficiaries’ access to care when reducing provider payment rates and adjusting payment methodologies under Medicaid.” However, the organizations expressed concern that the Rule does not go far enough.

Detailed recommendations were made on the following areas of concern:

Standardized and Transparent Process – Creation of a standardized process to measure Medicaid beneficiaries access to care, with support for CMS’ proposal to make the data analysis public.

Required Data Elements – Require states to submit cost studies as part of their access review along with data on the number of physicians accepting new Medicaid patients, emergency room utilization and data on the patient/physician ratio in Medicaid compared to private insurance plans.

Stakeholder Input & Enforcing State Compliance – Require states to develop procedures to seek input from stakeholders prior to submitting a state plan amendment that proposes to reduce or restructure payment rates, and to monitor access to services after a change in payment rates has been implemented.

Managed Care –Develop a rule for Medicaid managed care as expeditiously as possible, because the Rule, as currently written, does not apply to Medicaid managed care even though a majority of Medicaid beneficiaries receive at least a portion of their health care through a managed care plan.

Click here to read the letter.