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Medicaid Managed Care Rule Causes Concerns for Providers

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Industry: Health Care

Key Facts

  • Our clients are national providers of Medicaid Managed Care Services
  • In April 2016, CMS adopted a new Medicaid Managed Care Rule
  • We continue to work with clients on options for approaching states on implementing Medicaid Managed Care provider enrollment processes

The Situation

Our clients are national providers of Medicaid managed care services for multiple different Medicaid managed care plans in multiple states. In April 2016, CMS adopted a new Medicaid Managed Care Rule. Among its many provisions was a mandate for states to adopt Medicaid provider screening / enrollment requirements for Medicaid managed care providers by July 2018. In 2016, Congress inserted a provision in the 21st Century Cures Act that mandated states implement Medicaid managed care provider enrollment requirements consistent with the Medicaid Fee-for-Service requirements no later than January 1, 2018.  CMS didn't address the inconsistencies in Medicaid managed care provider enrollment requirements, nor did CMS warn states that the 21st Century Cures Act advanced the deadline for Medicaid managed care provider enrollment.

The Approach

Mintz reached out to several advocacy groups that had attempted to address the inconsistent federal requirements on Medicaid managed care provider enrollment, but learned CMS had not substantively responded. We then made direct contact with responsible CMS officials and pressed whether the agency would authorize states and managed care organizations to utilize any of the enrollment short-cut options endorsed by the Medicaid Managed Care Rule, including use of Temporary Network Provider Agreements. In advance of the January 1, 2018 deadline, we drafted a form Temporary Network Provider Agreement that the clients could execute that would, in essence, authorize continued Medicaid managed care billings.

The Outcome

CMS confirmed that it would recognize the validity of Temporary Medicaid Managed Care Network Provider Agreements and would consider those agreements as compliant with the federal Medicaid managed care provider enrollment requirement. We continue to work with clients on various options for approaching states on adopting / implementing Medicaid managed care provider enrollment processes that recognize the differences between an initial Medicaid Fee-for-Service provider enrollment and a secondary Medicaid managed care provider enrollment.

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