Bill Cuts Medicaid Directly, Medicare Indirectly
Admin by Tim Rowan, Editor Emeritus Bill Cuts Medicaid Directly, Medicare Indirectly This is what online publishers call a “living article.” With the House and Senate passing different bills, progress toward the President’s desk changes by the hour. What...Medicaid Cuts Update: Meet the Senate Parliamentarian
Admin by Tim Rowan, Editor Emeritus Medicaid Cuts Update Senate Parliamentarian Elizabeth MacDonough The ongoing negotiations in Congress will impact Medicaid and Medicare. There has been little movement from the Senate since we reported on this last week, but here’s...Medicaid Cuts Still Looming
Clinical by Tim Rowan, Editor Emeritus Medicaid Cuts Looming Terminal Prognosis Let me tell you about my brother. In his early 30’s, Tom was diagnosed with a rare disorder, one of the 25 versions of Ataxia. A disorder that is sometimes genetic, sometimes of unknown...Medicaid Cuts Remain Unknown So Far
CMS by Tim Rowan, Editor Emeritus "Life and Death" Medicaid Cuts are Looming We don’t need to cut benefits, and it really infuriates me to hear people here talking about that because it stresses people out. This is life and death for them. –Senator Bernie Moreno...Is Medicaid Down for the Count?
Breaking News by Kristin Rowan, Editor Medicaid Payment System Goes Dark On Monday, January 27, President Trump, through the Office of Management and Budget, announced a temporary freeze on federal spending while his newly designated head of the Department of Government Efficiency...Care at Home Coming to Medicaid?
Advocacy by Elizabeth E. Hogue, Esq. Brown v D.C. Decision is Another Boost for Care at Home In Olmstead v. L.C., the U.S. Supreme Court decided that unjustified segregation of disabled persons constitutes discrimination in violation of Title II of the Americans with...Biden Budget Impacts Medicare and Medicaid
From the NAHC Newsdesk, March 12, 2024 On Monday, March 11th, President Biden released a $7.26 trillion proposed budget for fiscal year (FY) 2025, which begins October 1st, 2024. While the White House budget is simply a request and Congress has final say on government...CMS Issues Medicaid Guidance on Change Healthcare Hack
CMSFrom the NAHC News Desk,
March 19, 2024
On March 15th, the Centers for Medicare & Medicaid Services (CMS) issued a Center Informational Bulletin (CIB) that provides guidance and flexibilities to mitigate the impacts on providers resulting from the Change Healthcare Hack. In the guidance, CMS advises state Medicaid agencies that certain requirements will not be enforced, until June 30th, to enable ongoing funds to flow to providers and to prevent disruption of access to Medicaid services, prevent associated negative health outcomes, and avoid solvency issues for providers.

The most important component of the guidance is the ability for states to make interim payments to providers to avoid operational disruptions. Federal law and regulation does not allow for “advance payments” in Medicaid fee-for-service systems, despite their availability in Medicaid managed care environments; however, states can make interim payments to providers subject to reconciliation with actual services delivered.
CMS stresses that such interim payments are not advanced payments or prepayments prior to services furnished by providers, but rather are payments for services furnished that are subject to final reconciliation once the state has access to individual claims data currently inaccessible due to the cybersecurity incident.
The flexibilities CMS discusses in the guidance include:
- Modifying required timelines for public notice, public process, and Tribal consultation and to obtain an earlier effective date for certain kinds of SPAs than would otherwise be possible;
- Use interim payment methodologies to pay providers without current period claims data, as long they are determined via current approved payment rates, limiting the interim payments to the amount expected for each specific provider based on recent history, and reconciling the interim payments with final payments based on the actual services provided once they can be properly identified. These could be effective retroactively to the date when claims payment processing was disrupted due to the cybersecurity incident and could last until June 30, 2024;
- Suspend beneficiary cost sharing requirements described in their state plans when necessary to avoid service disruptions for Medicaid beneficiaries for services affected by the hack;

CMS also includes language urging Medicaid managed care plans to make prospective payments to impacted providers and reiterating that plans do not need prior CMS authority to make prospective payments to providers. CMS also indicates that plans can:
- Suspend or modify prior authorization requirements;
- Allow early prescription refills and/or extend the length of prescription refills;
- Extend existing prior authorizations;
- Suspend out-of-network requirements; and
- Modify or update cost-sharing requirements to be consistent with any changes that are made in the Medicaid state plan.
The full guidance is available online at: https://www.medicaid.gov/sites/default/files/2024-03/cib031524.pdf.


