Keeping Regulations Affecting Medicaid on the Forefront

ENGAGEMENT WITH REGULATORY AGENCIES

May 18, 2022 -

MHPA Seeks Clarity from FCC Director on Allowances and Immunities under the Telephone Consumer Protection Act (TCPA)

In a letter to FCC Chairwoman Jessica Rosenworcel, MHPA requested clarity on the FCC's interpretations of the TCPA to remove barriers to Medicaid beneficiary outreach through electronic means. This action would help protect access to health coverage and minimize coverage gaps for this vulnerable population when the COVID-19 public health emergency ends.

READ LETTER

May 18, 2022 -

MHPA Responds to Administration's Request for Information on Permissible Text Messages, Calls Under the Telephone Consumer Protection Act

MHPA and several other health care organizations wrote a letter to Federal Communications Commission (FCC) Chairwoman Jessica Rosenworcel in response to the FCC request for comment on the U.S. Department of Health and Human Services' (HHS) request for clarification that certain automated calls and text messages or prerecorded voice calls relating to enrollment in state Medicaid and other governmental health coverage programs are permissible under the Telephone Consumer Protection Act (TCPA). MHPA and the other health care organizations urged the FCC to issue guidance and clarify the TCPA to avoid barriers to health coverage-related communications to Medicaid and other health program enrollees.

READ LETTER

April 21, 2022 -

MHPA Responds to Administration's Request for Information on Access in Medicaid and CHIP

MHPA provided detailed strategies and solutions, with a focus on health equity, to expanding access to coverage and care in Medicaid and the Children's Health Insurance Program (CHIP).

READ LETTER

April 1, 2022 -

MHPA, Other Health Care Organizations Send Letter to CMS Director Reiterating Need for 120 Days' Prior Notice to Wind Down of FMAP & MOE Continuous Eligibility Provisions 

In our continuing effort to support health plans, states, and providers who are working to ensure Medicaid enrollees avoid dangerous or unnecessary gaps in coverage and care, MHPA and several other health care organizations wrote a letter to the Centers for Medicare and Medicaid Services (CMS) Director Chiquita Brooks-LaSure, reiterating the need for 120 days' prior notice before the wind down of FMAP and Maintenance of Effort provisions included in the Families First Coronavirus Response Act.

READ LETTER

February 23, 2022 -

MHPA Sends Letter to CMS Director With Comments on Medicaid Managed Care Rate Development Guide

MHPA wrote a letter to the Centers for Medicare and Medicaid Services (CMS) in response to the CMS request for comment on the revision of the currently approved collection of information for the Medicaid Managed Care Rate Development Guide (the Guide). The Guide is an important resource for states, Medicaid health plans, and stakeholders.

READ LETTER

February 10, 2022 -

MHPA Seeks Clarity from CMS Director on Medicaid Coverage of Monoclonal Antibodies Directed Against Amyloid for the Treatment of Alzheimer's Disease, including FDA-Approved Aduhlem

In a letter to Chiquita Brooks-LaSure, Administrator for the Centers for Medicare and Medicaid Services (CMS), MHPA requested clarity regarding Medicaid coverage of Food and Drug Administration (FDA) approved monoclonal antibodies (mAbs) that target amyloid for the treatment of Alzheimer's disease, including FDA-approved Aduhelm. MHPA urged CMS to provide further guidance to state Medicaid programs to ensure clarity of utilization management criteria and medical necessity criteria, and asked that CMS offer risk mitigation options to minimize the impact of cost-shifting from Medicare.

READ LETTER

January 5, 2022 -

MHPA Sends Letter to Director of the Division of Managed Care Policy about Risk Mitigation

MHPA wrote a letter to the Director of the Division of Managed Care Policy for the Centers for Medicaid and CHIP Services at the Centers for Medicare and Medicaid Services (CMS) about identifying and implementing best practices that ensure individuals retain health coverage as the Public Health Emergency (PHE) comes to a close.

READ LETTER

NOVEMBER 4, 2021 -

MHPA Sends Letter to CMCS Director About the Unwinding of the COVID-19 Public Health Emergency

MHPA wrote a letter to the Centers for Medicare and Medicaid Services (CMS)/Center for Medicaid and CHIP Services (CMCS) with key takeaways from their most recent quarterly call in September.

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July 30, 2021 -

MHPA Sends Letter to CMCS About the Public Health Emergency, Health Equity and the Medicaid Managed Care Final Rule

MHPA wrote a letter to the Centers for Medicare and Medicaid Services (CMS)/Center for Medicaid and CHIP Services (CMCS) with key takeaways from their most recent quarterly call in June.

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May 27, 2021 -

MHPA Sends Letter to CMS With Comments on Medicaid Managed Care Rate Development Guide 

MHPA wrote a letter to the Centers for Medicare and Medicaid Services (CMS) in response to the CMS request for comment on the revision of the currently approved collection of information for the Medicaid Managed Care Rate Development Guide (the Guide).

READ LETTER

April 27, 2021 -

MHPA, Other Organizations Send Letter to CMS on Extending Postpartum Medicaid Coverage

MHPA and 14 other organizations sent a letter to Elizabeth Richter, Acting Administrator of the Centers for Medicare and Medicaid Services (CMS), urging CMS to work with states to implement waivers that extend continuous, comprehensive coverage to 12 months postpartum.

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February 5, 2021 -

MHPA Signs National Letter to HHS re: Post-Partum Coverage in 1115 Waivers

MHPA sent a letter to HHS with nearly 300 state and national organizations urging approval of section 1115 waivers aimed at extending postpartum coverage for individuals who were enrolled in Medicaid while pregnant to a full year after the end of pregnancy.

READ LETTER

December 23, 2020 -

MHPA Letter to HHS on "Reducing Provider and Patient Burden" Proposed Rule

MHPA sent a letter to HHS Secretary Azar and CMS Administrator Verma expressing "serious concerns with the timeframe for providing comments and responding to the requests for information" on the Reducing Provider and Patient Burden by Improving Prior Authorization Processes proposed rule. The proposed rule (CMS-9123-P) contained an abnormally short 25-day comment period.

READ LETTER

December 21, 2020 -

Group Letter to CMS on "Reducing Provider and Patient Burden" Proposed Rule

MHPA joined a letter with other leading national associations calling on CMS to "pause work on this rule as the nation continues to focus on the response to the COVID-19 pandemic." The proposed rule (CMS-9123-P) contained an abnormally short 25-day comment period.

READ LETTER

December 17, 2020 -

Key Group Letter to Biden Transition on PHE Declaration Extension

MHPA joined a letter with other leading national associations calling on President-elect Biden and the transition team to convene states and stakeholders to develop a set of publicly reported metrics or milestones that will inform future decisions around the COVID PHE declaration.

READ LETTER

December 14, 2020 -

MHPA Sends Letter to Biden-Harris Transition Team

MHPA’s letter requests action on several legislative and regulatory priorities in 2021 for the new Administration.

November 20, 2020 -

Comments to CMS’ Request for Information: Recommended Measure Set for Medicaid-Funded Home and Community-Based Services

A joint letter from MHPA, National MLTSS Health Plan Association, AHIP, and the Blue Cross Blue Shield Association.

November 16, 2020 -

Medicaid Managed Care Rule - MHPA Comments/CMS Actions

Topline summary and side-by-side comparison.

October 1, 2020 -

Letter to CMS Requesting an Extension of CMS HCBS RFI Deadline

MHPA joined a letter with several other health care trade associations requesting that CMS extend the deadline for the Request for Information (RFI) on the Recommended Measure Set for Medicaid-Funded Home and Community-Based Services (HCBS). The letter states, “as the national trade associations representing health insurance providers at the state and federal level who serve hundreds of millions of Americans every day, we welcome the opportunity to respond to the questions posed in the RFI.” The letter requests a 30-day extension of the comment deadline.

READ LETTER

September 22, 2020 -

MHPA Sends COVID-19 Transition Planning Issues and Recommendations to CMCS

MHPA sent COVID-19 transition planning recommendations to the Center for Medicaid and CHIP Services (CMCS) in an effort to ensure that the health care needs of Medicaid beneficiaries will continue to be met in an appropriate and timely manner after the expiration of the public health emergency (PHE).

 

READ LETTER

VIEW TABLE

August 7, 2020 -

MHPA Joins Groups Sending Comments to CMS on HCBS Rebalancing and Nursing Home Diversification

MHPA joined with five other national trade associations representing health insurance providers at the state and federal level to provide input on HCBS, rebalancing, and nursing home diversification.READ LETTER

July 20, 2020 -

MHPA Sends Comments to CMS-2482-P- Proposed Rule: Medicaid Program; Establishing Minimum Standards in Medicaid State Drug Utilization Review (DUR) and Supporting Value-Based Purchasing (VBP) for Drugs Covered in Medicaid, Revising Medicaid Drug Rebate and Third Party Liability (TPL) Requirements

MHPA sent comments to CMS Administrator Seema Verma for the proposed rule, Medicaid Program; Establishing Minimum Standards in Medicaid State Drug Utilization Review (DUR) and Supporting Value-Based Purchasing (VBP) for Drugs Covered in Medicaid, Revising Medicaid Drug Rebate and Third Party Liability (TPL) Requirements.
READ LETTER

July 20, 2020 -

MHPA Sends Medicaid Provider and Plan Letter on MFAR's Impact to HHS/CMS

MHPA joined with six other national organizations sending a letter requesting that the Department of Health and Human Services and the Centers for Medicare and Medicaid Services (CMS) pause work on the Medicaid Fiscal Accountability Rule (MFAR) during this time of COVID-19 and urge thoughtful consideration of the long-term impact of the policy.
READ LETTER

July 9, 2020 -

Letter to CMCS regarding Safeguarding Medicaid Program Sustainability through State-Medicaid Managed Care Partnerships

MHPA sent a letter to CMCS Director Calder Lynch requesting that CMS issue guidance to help protect the continued viability of state-Medicaid managed care partnerships and the long-term sustainability of the Medicaid program. - READ LETTER

May 29, 2020 -

RFI Response regarding Maternal and Infant Health Care in Rural Communities

MHPA responded to the Office of Minority Health’s (OMH) request for information (RFI) regarding maternal and infant care in rural communities. The letter commended the Committee's continued leadership and commitment to improving health care access, quality, and outcomes for women and infants in our nation’s rural communities. - READ LETTER

May 8, 2020 -

Letter to HHS Secretary, Medicaid Directors on Supporting Critical Medicaid Providers 

MHPA joins with seven other organizations in writing HSS Secretary Azar to urge for the urgency of expeditiously delivery federal financial relief to Medicaid providers and to offer ongoing assistance for future action. - READ LETTER

May 8, 2020 -

Letter on CARES Act Funding and Medicaid Providers Sent to HHS Secretary

MHPA sent a letter to Secretary Azar offering recommendations and to encourage taking action to ensure access to care today and in the future for the vulnerable Medicaid and Dually Eligible populations who access care and services through the Medicaid health care delivery system. - READ LETTER

May 4, 2020 -

Letter to FCC Regarding Lifeline Program and Responses to the COVID-19 Pandemic

MHPA joined with other organizations in requesting that the Federal Communications Commission (FCC) consider certain actions to expand the availability of the Lifeline program during the current COVID-19 public health emergency. - READ LETTER

March 23, 2020 -

Response Letter to to the HHS Secretary and CMS Administrator on Coordinating Care from Out-of-State Providers for Medicaid-Eligible Children with Medically Complex

RIN 0938-ZB57 - Request for Information - CMS-2324-NC  - READ LETTER

March 11, 2020 -

Letter to CMS on COVID-19

January 31, 2020 -

MHPA Comments on Medicaid Fiscal Accountability in Proposed Regulation

Federal Register, Vol. 84, No. 222, November 18, 2019 [CMS-2393-P] and Federal Register, Vol. 84, No. 249, December 30, 2019 [CMS-2393-N] - READ LETTER

January 13, 2020 -

Letter to Center for Medicaid and Chip Services (CMCS)

Use of Underwriting Gain Assumption Models & Suggested Additions to 2020-2021 Medicaid Managed Care Rate Setting Development Guide . - READ LETTER

December 19, 2019 -

MHPA Sends Letter to CMS Asking for Extension to Comment Period

Concerned over the limited timeframe available for stakeholders to offer meaningful comments before the mid-January deadline, MHPA sent its own letter to CMS asking for an extension to the comment period given the complexity of the Medicaid regulation proposals can have on beneficiaries and the current health care delivery system. - READ LETTER

December 18, 2019 -

MHPA Joins with Partnership for Medicaid to Request CMS Extend Rulemaking Comment Period for 60 Days

MHPA  joined with the Partnership for Medicaid to request CMS extend the Medicaid fiscal accountability NPRM comment period for 60 days, time necessary to offer more meaningful comments and to fully assess the impact that these changes will have on the Medicaid Program and state budgets. - READ LETTER

November 7, 2019 -

MHPA Letter on CMCS Informational Bulletin

Medical Loss Ratio (MLR) Requirements Related to Third-Party Vendors - READ LETTER

June 3, 2019 -

MHPA Submit Comments to CMS on Two Comprehensive Regulations

MHPA Comments to CMS–9115–P; Medicare and Medicaid Programs; Patient Protection and Affordable Care Act; Interoperability and Patient Access for Medicare Advantage Organization and Medicaid Managed Care Plans, State Medicaid Agencies, CHIP Agencies and CHIP Managed Care Entities, Issuers of Qualified Health Plans in the Federally-Facilitated Exchanges and Health Care Providers.  As well as Comments to RIN 0955–AA01; 21st Century Cures Act: Interoperability, Information Blocking, and the ONC Health IT Certification Program - READ LETTER

April 8, 2019 -

MHPA Comments on Fraud & Abuse, Safe Harbor Proposed Rules

MHPA Comments to OIG-0936-P;  Proposed Rule: Fraud & Abuse; Removal of Safe Harbor Protection for Rebates Involving Prescription Pharmaceuticals and Creation of New Safe Harbor Protection for Certain Point-of-Sale Reductions in Price on Prescription Pharmaceuticals and Certain Pharmacy Benefit Manager Service Fees. - READ LETTER

January 14, 2019 -

MHPA Comments to CMS on Proposed Rule for the Medicaid and CHIP

Medicaid Program; Medicaid and Children’s Health Insurance Plan (CHIP) Managed Care - READ LETTER

December 31, 2018 -

MHPA Response to Policy and Technical Changes to the Medicare Advantage, Prescription Drugs

Medicare and Medicaid Programs; Policy and Technical Changes to the Medicare Advantage,
Medicare Prescription Drug Benefit, Program of All-Inclusive Care for the Elderly (PACE),
Medicaid Fee-for-Service, and Medicaid Managed Care Programs for Years 2020 and 2021 - READ LETTER

July 31, 2018 -

MHPA Comments on Title X

Family Planning Program - Title X Notice of Rulemaking - READ LETTER

July 18, 2018 -

MHPA Comments on Drug Pricing

HHS Blueprint to Lower Drug Price and Reduce Out-of-Pocket Costs - READ LETTER

April 12, 2018 -

MHPA's Comments on Implementing the Dual Eligible Special Needs Plans (D-SNPs)

Comments on Section 50311. Request for Stakeholder Input(RFI) entitled “Implementing the Dual Eligible Special Needs Plans (D-SNPs) Provisions of the Bipartisan Budget Act of 2018 (Public Law No. 115-123)” issued on March 13, 2018. MHPA applauds CMS’ efforts to strengthen integration of care for dual eligible beneficiaries and to develop unified processes across programs to ensure access to seamless, coordinated care for vulnerable beneficiaries. - READ LETTER

January 16, 2018 -

MHPA Comments on Medicare Program

CMS-4182-P: Medicare Program; Contract Year 2019 Policy and Technical Changes to the Medicare Advantage, Medicare Cost Plan, Medicare Fee-for-Service, the Medicare Prescription Drug Benefit Programs, and the PACE Program Proposed Rule - READ LETTER

October 17, 2016 -

MHPA Comments on the Proposed PACE Rule

MHPA believes that PACE Organizations (POs) and Medicaid MCOs play a key role in providing integrated acute and long-term services and supports (LTSS) to complex, vulnerable populations. - READ LETTER

State Waivers

August 17, 2018 -

KY 1115 MHPA Waiver Comments

January 5, 2018 -

NC 1115 MHPA Waiver Comments

Resources