ANCOR Submitted Formal Comments on Provider Tax Proposal; Other Stakeholders Share Their Reactions

As an update on our call to action on the Center for Medicare and Medicaid Services’ (CMS) proposed Medicaid Fiscal Accountability Regulation (MFAR), we are making available the comments we formally submitted on January 31 on the topic. We wish to thank the 138 advocates who also submitted comments in response to our call to action. We will keep our readers informed of future developments and opportunities for action on this topic.

As written in ANCOR’s comments:

“While ANCOR supports the stated goals of ensuring that Medicaid resources are expended consistent with federal requirements and standards related to quality, economy, and efficiency, as well as the focus on transparency, we also have concerns that the rule could result in substantial reductions in Medicaid funding in many states, which will put programs and people at risk. We are also deeply concerned that the response by states to less funding might be to cut existing services.  The risk to Home and Community Based Services is great.  While these services are critical to the I/DD population, they are still regrettably classified as “optional” rather than “mandatory.”  Medicaid is an essential source of support for people with disabilities, yet providers of these services operate with little to no margin or wiggle room.  Reimbursement rates are inadequate, as evidenced by an astonishingly high Direct Support Professional (DSP) turnover rate of 51.3% nationally.  Any loss of funding in the overall Medicaid program would jeopardize disability service providers’ ability to ensure the continued delivery of critically important services and supports.”

To keep our members aware of reactions to the proposal in the broader community, we are also sharing the National Governors Association’s (NGA) comments.

As stated in the NGA letter:

“Governors request that CMS not move forward with the current proposed rule, as written, and instead, gather more data to understand the impact, identify more targeted evidence-based policies to address concerns and work with states to determine best practices for how to strengthen accountability and transparency in the Medicaid program. Medicaid plays a significant role for millions of people across the country and its complex structure warrants careful and thoughtful steps for any reform.”