Should Your Organization Submit Comments Regarding the Proposed CMS Medicaid Managed Care Rules?

June 17, 2015

On June 1, 2015, the Centers for Medicare and Medicaid Services (“CMS”) published proposed regulations that will impose comprehensive changes on the Medicaid managed care system, including its behavioral health providers and payers.

The proposed regulations include measures to address the following areas of special interest to the behavioral health community: (a) align Medicaid managed care plan standards with those applicable to commercial markets, Medicare Advantage plans and Exchanged-based Qualified Health Plans; (b) impose new Medical Loss Ratio (MLR) standards; (c) require compliance with new provider network adequacy standards, (d) impose new quality of care measurement standards and a quality rating system; (e) make changes to the actuarial soundness provisions; and (f) improve beneficiary protections.

When final, these rules will have a sweeping impact on the behavioral health community of providers and payers, alike. CMS is accepting comments on the proposed rules, which may be submitted by mail or electronically, through July 27, 2015. The submission of thoughtful, relevant comments is one way in which the behavioral health community can inform CMS about potentially troubling aspects of the proposed rules, ultimately helping to shape the rules’ final form.

If you have any questions, Dykema attorney Roselyn (Roz) Parmenter (734-214-7612 or and other members of the Dykema Health Care Practice Group are available to assist your organization in understanding the proposed Medicaid Managed Care rules, and submitting comments to address areas of special significance.

As part of our service to you, we regularly compile short reports on new and interesting developments and the issues the developments raise. Please recognize that these reports do not constitute legal advice and that we do not attempt to cover all such developments. Rules of certain state supreme courts may consider this advertising and require us to advise you of such designation. Your comments are always welcome. © 2021 Dykema Gossett PLLC.