The rules are still a proposal; the Department of Health and Human Services will accept comments on them through the end of July prior to issuing the final rules. While it is true that final responsibility for accepting or rejecting the rules rests with the states, we believe that CMS’s proposed changes will have a significant impact on all stakeholders in the Medicaid space.
Because Medicaid is largely a procurement business – with states purchasing services from managed care organizations – we expect the new rules to have an impact on state requirements for procurement. Health plans will need to be thoughtful about how the regulations will impact current contracts, as well as those that are due for renegotiation.