We strongly support the overall direction CMS is taking in these rules to advance the important goals of improving access to services, increasing transparency and monitoring of access, improving quality reporting, and advancing health equity. Our comments are focused on aspects of the proposed rules that would further improve transparency across the health care system and more fully center the needs and interests of Medicaid beneficiaries at the heart of proposed changes, including:
• Strengthening the structure and makeup of the new Medicaid Advisory Committee (MAC) and Beneficiary Advisory Group (BAG) to be more consumer focused.
• Commending the person-centered service plan proposal.
• Expanding the definition of Home and Community-Based Services (HCBS) workers included in the rule to maximize appropriate compensation for the delivery of this critical care.
• Ensuring the HCBS Quality Measure Set collects appropriate demographic data to support efforts to advance health equity.
• Further increasing transparency of service payment rates.
Managed Care Rule:
• Supporting codification of setting the cap for state-directed payments at average commercial rates and requiring additional transparency around these payments.
• Maximizing effectiveness of enrollee experience surveys.
• Improving proposed appointment wait time standards for people in need of time-sensitive reproductive health services, including abortion care.
• Strengthening the provision to assure adequate capacity and services via provider payment analysis.
• Clarifying framework for different states to implement a Medicaid and CHIP quality rating system.