AHIP submitted comments to CMS on the proposed Medicaid Fiscal Accountability Regulation (MFAR). The MFAR addresses several methods that states use to finance Medicaid base and supplemental payments, including health care-related taxes and provider-related donations. The MFAR would also establish new reporting requirements for states to provide CMS with information on supplemental payments to Medicaid providers.
Our comments recognize the need for CMS to safeguard the fiscal integrity of the Medicaid program, but we express serious concern that the proposed restrictions could significantly hinder the ability of many states to fund their Medicaid programs, which could have harmful impacts on Medicaid beneficiaries and coverage.
Rather than move forward with the rule as proposed, we urge CMS to consider a more limited initial step, focusing on the collection of data necessary to fully assess the current landscape of state Medicaid funding and payment mechanisms. This would ensure CMS, states, and other affected parties have the time and information they need to assess the scope of existing concerns and the state-by-state impacts of potential restrictions, and to consider alternatives.