PHI Comments on Proposed Medicaid Managed-Care Regulations

Increasingly, states are contracting with private managed-care plans to provide health benefits and long–term services and supports (LTSS) to low-income individuals with Medicaid, instead of administering traditional fee-for-service coverage.

Due to this shift to Medicaid managed care, the Centers for Medicare and Medicaid (CMS) released on June 1 its first new proposed Medicaid managed-care regulations in over a decade.

These regulations set standards for health coverage as well as the LTSS system in which direct-care workers perform their essential roles.

PHI has reviewed the proposed CMS regulations and provided comment on those sections which impact LTSS consumers and the direct-care workers who support them. The main themes of PHI’s comments are:

1. For Medicaid enrollees to access high-quality LTSS, the wages, benefits, and training needs of direct-care workers should be explicitly considered in rate setting, quality measures, and other key aspects of the regulations.
2. While these regulations should manage costs in an improved managed-care system, they should also acknowledge that cost-effectiveness should not compromise the quality of care that enrollees receive. Proposed quality changes — including those in workforce training, job quality, and workforce stability — require an initial investment in resources and infrastructure.
3. To ensure that the improvements specified in these regulations become standard practice, PHI encourages stronger monitoring, enforcement, and accountability mechanisms at the state and federal level—notably in the areas of workforce support and training.
4. The unique needs of the LTSS population and the direct-care workers that serve them necessitates additional rules and regulations which are specific to this population.

PHI’s full comments are available at the PHI National Clearinghouse on the Direct Care Workforce.

— by Allison Cook, PHI New York Policy Associate