ENGAGEMENT WITH REGULATORY AGENCIES
January 27, 2025 -
MHPA Submits Letter to CMS Regarding Anti-Obesity Medications and Provisions Impacting Dually Eligible Enrollees
In a letter to the Centers for Medicare and Medicaid Services (CMS), MHPA expressed appreciation for the agency’s efforts to expand coverage of anti-obesity medications (AOMs) to the Medicaid program and advocated for CMS to delay the requirement that the Medicaid program cover AOMs until the first rating period after January 1, 2027. This delay would allow additional time for states to prepare for the impacts to their budgets, and for stakeholders to prepare for implementation.
MHPA also weighed in with considerations on several provisions impacting dually eligible enrollees, including a proposal to require Dual Eligible Special Needs Plans (D-SNPs) that are Applicable Integrated Plans (AIPs) to have integrated member ID cards, and a proposal to require D-SNPs that are AIPs to conduct a single integrated Health Risk Assessment (HRA) for Medicare and Medicaid.
READ THE LETTER
Dec. 2, 2024 -
MHPA Submits Letter to CMS in response to a Request for Comments on Templates for Documenting Compliance with Mental Health Parity in Medicaid and CHIP
MHPA submitted a letter to CMS in response to a Request for Comments on Templates for Documenting Compliance with Mental Health Parity in Medicaid and CHIP. Supporting access to behavioral and mental health care and services for Medicaid beneficiaries is of paramount importance to MHPA’s health plan members. In comments, MHPA applauded CMS’ transparent approach to supporting compliance with mental health parity requirements across health care delivery systems, highlighted nuances in state programmatic design, and expressed support for moving in the direction of using uniform tools to measure compliance as the agency adopts measures aimed at promoting consistency among states.
READ THE LETTER
Nov. 14, 2024 -
MHPA Submits Letter to CMS on Capitation Rate Setting
This letter to CMS discusses critical issues impacting capitation rate setting for Medicaid managed care organizations (MCOs). MHPA highlights trends creating significant pressure on rates, including shifting member acuity, state programmatic design, trend predictability, high-cost drugs, and inflation.
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Sept. 25, 2024 -
MHPA Submits Comments to CMS on Revised Nevada 1332 Waiver Application
In a letter to CMS Administrator Chiquita Brooks-LaSure, MHPA expressed concerns with the state of Nevada’s now revised 1332 Waiver application. After previously commenting on Nevada’s waiver application in March, the Association continues to recommend that CMS reject this waiver application and work with the state to develop an alternative 1332 waiver which improves access without negatively impacting provider participation and member choice in the state.
READ THE LETTER
Sept. 9, 2024 -
MHPA Submits Comments to CMS on CY2024 OPPS Proposed Rule
In a letter to CMS Administrator Chiquita Brooks-LaSure, MHPA addressed continuous eligibility (CE) for Medicaid and CHIP, Medicaid Reimbursement for certain services outside of a clinic, and minimum standards for hospital obstetric services.
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June 6, 2024 -
MHPA Submits Comments in Response to HHS RFI on Potential Viral Hepatitis Quality Measures in Medicaid
Despite the availability of effective treatments for hepatitis C (HCV), a recent study found that only one in five Medicaid enrollees diagnosed with HCV started treatment within six months of diagnosis. In response to a Department of Health and Human Services' (HHS) request for information (RFI), MHPA agrees that more needs to be done to increase treatment uptake and believes the development and implementation of meaningful quality measures focused on screening and treatment should be part of an overall strategy to support access to appropriate care, treatment, and services for Medicaid enrollees who test positive for viral hepatitis.
READ THE LETTER
March 20, 2024 -
MHPA Details Immediate Measures Taken by MCOs to Mitigate Effects of Recent Cyberattack
In a letter to HHS Secretary Xavier Becerra, MHPA details immediate steps that managed care organizations (MCOs) across the country are taking to mitigate the effects of the recent Change Healthcare cyberattack for beneficiaries and providers. In addition to ensuring that Medicaid beneficiaries did not suffer unnecessary disruptions in care, MHPA’s members are working closely with state partners to support the entire Medicaid provider infrastructure by making targeted advance payments, engaging in outreach to safety net providers, and offering ongoing assistance to provider partners switching to alternative payment and claims processing services. MHPA’s member managed care organizations (MCOs) remain committed to ensuring that vulnerable populations have access to quality, affordable, and effective health care.
READ THE LETTER
March 14, 2024 -
MHPA Comments on Nevada Section 1332 Waiver Application
In comments to Centers for Medicare and Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure, MHPA expressed concern that Nevada’s Section 1332 State Innovation Waiver could negatively impact choice and competition for Nevadans who receive health care through the individual market or the state Medicaid program. Additionally, the Association warns of the waiver’s detrimental impact on the state’s workforce shortage and lack of alignment with CMS’ goal of improving access and addressing provider workforce shortages, including in the Medicaid program.
READ THE LETTER
January 5, 2024 -
MHPA Submits Comments to CMS on Medicare Advantage, Part D Proposed Rule
In comments to the Centers for Medicare & Medicaid Services (CMS), MHPA expressed support for meeting the needs of dually eligible individuals, encouraged CMS to ensure that existing state efforts to meaningfully advance integration are protected, and asked CMS to consider that states with carve outs for behavioral health or long-term services and supports are in varying positions to meet alignment objectives.
READ THE LETTER
December 1, 2023 -
MHPA Submits Feedback on Request for Comments on Mental Health Parity in Medicaid and CHIP
Access to mental and behavioral health services is critical to ensuring whole person health for the vulnerable populations served by the Medicaid and CHIP programs. In a letter to the Centers for Medicare and Medicaid Services (CMS) in response to a request for comments on Mental Health Parity in Medicaid and CHIP, MHPA offered solutions to the behavioral health workforce shortage, highlighted the variation in programmatic design between State Medicaid Programs, and called for increased substance use disorder education to increase early identification and treatment.
READ THE LETTER
November 6, 2023 -
MHPA Submits Comments to CMS on LTC Minimum Staffing Standards, Institutional Payment Reporting, and Workforce Development
In comments to the Centers for Medicare & Medicaid Services (CMS), MHPA expressed support for workforce development for direct care workers as well as a requirement for LTC facilities to have a Registered Nurse on staff 24 hours/day.
READ THE LETTER
August 28, 2023 -
MHPA Submits Comments to CMS on the Development of Managed Long-Term Services and Supports Quality Measures
MHPA supports consistent reporting standards across organizations providing LTSS, including comprehensive measure development processes, audited results, and benchmarks for comparison. In response to a call from CMS for public input, MHPA expresses concerns and provides recommendations on a variety of areas including measure stratification, survey accessibility, state flexibility, dual-eligible populations, and more.
READ THE LETTER
July 25, 2023 -
MHPA Submits Comments to CMS on Proposed Updates to Medicaid Drug Rebate Program
In a letter to CMS Administrator Chiquita Brooks-LaSure, the Association expressed appreciation and provided recommendations for several proposals that would enhance efficiencies within the Medicaid Drug Rebate Program, specifically in the areas of unique identifiers, 3rd-party liability, drug cost transparency, and covered outpatient drugs.
READ THE LETTER
June 30, 2023 -
MHPA Submits Comments to CMS on Proposed Medicaid Managed Care, Access Regulations
In separate letters to CMS Administrator Chiquita Brooks-LaSure, MHPA reiterated the need for a reasonable implementation delay in enforcement of the proposed regulations to help ensure that states can fully focus their efforts on mitigation plans in the context of their redetermination efforts.
READ THE MANAGED CARE LETTER
READ THE ACCESS LETTER
June 13, 2023 -
MHPA Seeks Extension to Managed Care, Access NPRMs
In a letter to CMS Administrator Chiquita Brooks-LaSure, MHPA requested a 30-day extension on the comment period for CMS's Managed Care and Access NPRMs. MHPA expressed support for CMS in its stated goal of improving access and quality of care for Medicaid and CHIP enrollees and shared concerns that stakeholders would be unable to robustly engage on the proposed changes, given state, provider, and plan bandwidth constraints relating to the unwinding of continuous coverage requirements from COVID-19 era legislation.
READ LETTER
April 24, 2023 -
MHPA Comments on Managed Care Rate Development Guide
In comments today on the Centers for Medicare and Medicaid Services’ (CMS) proposed revision to the Managed Care Rate Development Guide, MHPA expressed concerns and encouraged the agency to include the establishment of clear risk-sharing arrangements prior to the rate period, clarity on the treatment of COVID-19 impacted data, and transparency in rate range development and underwriting gain assumptions.
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March 20, 2023 -
MHPA Submits Letter to CMS on Risk Mitigation
In response to data collection efforts addressing how states managed risk during the COVID-19 pandemic, MHPA encouraged the Centers for Medicare and Medicaid Services (CMS) to consider risk mitigation arrangements in the context of the full actuarial landscape unique to each state and the significant investments Medicaid MCOs make to address social determinants of health.
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Feb 9, 2023 -
MHPA Submits Follow-up Letter to CMCS on Medicaid Access Discussions
In a letter to CMCS, MHPA compiled the key takeaways from our recent conversations and included additional information on issues that required follow-up in the body of this letter and in the appendix. Specifically, this letter covers the following topics: Key Considerations for Defining and Measuring Access; Overview of Health Plan Monitoring and Reporting Tools; Wait Time Standard Considerations; and Related Corresponding Policy Positioning.
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Nov 11, 2022 -
MHPA Submits Letter to CMCS on Actuarial Soundness & Transparency Post COVID-19 Pandemic/Public Health Emergency Planning
In a letter to CMCS, MHPA presented considerations for rate setting in support of actuarial soundness and transparency, as CMS and CMCS prepare to unwind the COVID-19 public health emergency (PHE).
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Nov 7, 2022 -
MHPA Submits Letter to HHS, CMS in Response to NPRM on Medicaid Application, Eligibility, Enrollment Processes
In a letter to HHS Secretary Xavier Becerra and CMS Administrator Chiquita Brooks-LaSure, MHPA CMCS, MHPA expressed support for streamlining processes related to Medicaid applications, eligibility determinations, and enrollment while addressing concerns, challenges with state implementation timeframes and technology.
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October 24, 2022 -
MHPA Submits Letter to HHS in Response to the Reopening of the Interim Final Rule (IFR)
In a letter to HHS, MHPA presented comments re: the temporary increase in Federal Medical Assistance Percentage (FMAP), in response to the COVID–19 Public Health Emergency(PHE); Reopening of Public Comment Period.
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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.
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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.
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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).
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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.
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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.
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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.
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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.
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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).
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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.
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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.
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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.
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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.
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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.
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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).