We have been busy working on our comments on the proposed rule that would make significant changes to the Medicaid Access Rule. As my colleague, Andy Schneider, wrote last month, one of the major changes in the proposed rule is to allow states to make fee-for-service payment cuts of 4% a year (6% over two years, 12% over four, etc.) without reviewing their impacts on access and regardless of whether the payment rates being cut are already too low. Under the proposed rule, the 4% and 6% thresholds would apply to “overall service category spending.” The service categories are those generally defined under sections 1905(a)(1) through (29) of the Social Security Act. EPSDT , the Medicaid pediatric benefit, is in the same overall service category as nursing facility services, family planning services and supplies, and tobacco cessation services for pregnant women. Using national FY 2016 expenditure reports from MBES/CBES, we modeled a 4 percent payment reduction to the o
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