ACP Provides Comment to CMS on Improving Access to Care in Medicaid and CHIP

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In response to Request for Information, ACP urges CMS to preserve coverage for Americans after the public health emergency and address social drivers of health

May 20, 2022 (ACP) — In response to a request for guidance about the future of Medicaid, the American College of Physicians is advising federal medical officials to preserve coverage for millions, address care gaps that affect Black and Hispanic people and reduce physician paperwork.

Overall access is also crucial, ACP believes. “Medicaid needs to ensure that enrollees have real access to the care they need,” said Ryan Crowley, ACP senior associate for health policy. “Stronger network adequacy standards, oversight of managed care organizations and sufficient reimbursement for physicians will help improve access.”

The Centers for Medicare & Medicaid Services announced in February that it wants feedback from a diverse group of stakeholders on improving access to care in Medicaid. The agency says responses will “help inform future polices, monitoring, and regulatory actions, helping ensure beneficiaries have equitable access to high-quality and appropriate care across all Medicaid and [Children's Health Insurance Program (CHIP)] payment and delivery systems, including fee-for-service, managed care, and alternative payment models.” Responses, it said, “will also inform CMS’ work to ensure timely access to critical services, such as behavioral health care and home and community-based services.”

In an eight-page letter response dated April 18, ACP highlighted that millions of people could abruptly lose Medicaid coverage after the pandemic public health emergency ends. “Medicaid and CHIP are crucial parts of the U.S. health care system, with about 87 million enrolled in the programs,” Crowley said. “Enrollment in Medicaid really grew after the Affordable Care Act expanded eligibility to more adults, and the program has proven to be a lifeline during the COVID-19 pandemic.”

As part of its focus on access, ACP also encouraged Medicaid to address social drivers of health. “Black and Hispanic enrollees are less likely than their White counterparts to use a physician's office as their usual source of care,” Crowley explained.

The letter says that ACP “appreciates Medicaid's existing efforts to address social drivers of health and health equity and strongly recommends that Medicaid continue to comprehensively address the interconnected contributors to health and health care disparities, including the role of racism, discrimination, lack of coverage and access to care, and poverty.”

ACP also emphasized the need to continue telehealth flexibilities beyond the public health emergency, and it recommended some policy changes to encourage primary care and behavioral health integration.

“There are substantial barriers to integrating behavioral health and primary care, like workforce challenges and high upfront costs for practices,” Crowley said. “But there seems to be some political and policy support behind reform, so hopefully we'll see more states trying out new models.”

Appropriate reimbursement also remains a challenge in Medicaid, as the letter notes. According to Crowley, the average Medicaid fee-for-service reimbursement rate for primary care is 66% of what Medicare pays. In Rhode Island, it is 33% of Medicare.

“That's just not economically viable for a lot of practices,” he said. “ACP has pushed for permanently raising Medicaid primary care reimbursement to at least the level of Medicare. Doing so will encourage more physicians to participate in the program and improve access to care for patients.”

In the letter, ACP writes: “The evidence clearly demonstrates that physician participation in Medicaid is tied to reimbursement rates … We urge Medicaid to support sufficient reimbursement for primary care and specialty physicians.”

Finally, “we also expressed the need to reduce administrative burdens in Medicaid, especially prior authorizations and claim denials,” Crowley said.

Specifically, ACP urged CMS to streamline or eliminate prior authorizations (PAs). During the pandemic, ACP noted, “many states lifted PA requirements for medications. Medicaid should encourage states to extend these policies to increase access to prescription drugs for patients and alleviate the administrative burden for physicians.”

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Back to the May 20, 2022 issue of ACP Advocate