Medicaid directors concerned about CMS’ plans for measuring access to care

Medicaid directors are worried that CMS’ recent request for input relating to methods for measuring Medicaid enrollees’ access to care indicates that the agency intends to impose federal regulatory requirements that are out of touch with the complex issues facing state programs. In a letter to CMS, the National Association of Medicaid Directors (NAMD) detailed its members’ concerns that the request for information (RFI) signals the agency’s intention to limit the states’ ability to design payment methodologies by tying access to care with reimbursement rates.

Access measures

After the country’s economic downturn, states sought to dramatically reduce Medicaid provider payments. When CMS requested information from states relating to whether access to care would be maintained after payments were reduced, it found that in many instances the states’ processes for documenting access to care was inadequate. As a result, the agency issued a Final rule that would require states to create monitoring review plans to address whether the enrollees’ needs are being met (see States required to create access review framework for Medicaid programs, Health Law Daily, November 2, 2015).

Input requested

To determine how to meaningfully demonstrate sufficient access to care in state Medicaid programs, CMS issued an RFI that sought public input on: (1) access to care data collection and methodology; (2) access to care thresholds and goals; (3) alternative processes for access concerns; and (4) access to care measures.


NAMD expressed various concerns about the RFI and said state Medicaid agencies should have the authority to determine reimbursement rates and access thresholds because of the diversity among the states’ delivery system designs, populations, and provider networks. It added that states are already required to comply with significant reporting requirements on various aspects of their programs, and therefore CMS should use existing data sources and minimize further reporting requirements.

National standards

The organization also opposed the creation of a national core measure set and a national threshold for access to care, which, it argues, could impede ongoing delivery system and payment reform efforts and would be unlikely to generate meaningful comparisons across diverse state programs. It argued that alternative processes for access concerns are unnecessary because states already have tools in place to detect access problems. However, if additional processes are to be established, CMS should work with states to identify ways to improve the processes.


CMS should instead work with states in developing access to care measures that are necessary to fill in any data gaps. The measures must be sufficiently flexible to account for sate provider capacity variations and should incorporate telehealth initiatives and should keep pace with evolving technology.