On January 27, 2023, the Centers for Medicare & Medicaid Services released a State Health Official (SHO) letter, “Medicaid Continuous Enrollment Condition Changes, Conditions for Receiving the FFCRA Temporary FMAP Increase, Reporting Requirements, and Enforcement Provisions in the Consolidated Appropriations Act, 2023.” The SHO letter is the second in a series of guidance related to section 5131 of the Consolidated Appropriations Act, 2023 (CAA), which established a fixed end date for the Medicaid continuous coverage requirement, a gradual phase-down for the enhanced federal match, and new guardrails for mitigating coverage loss for individuals who continue to be eligible. This expert perspective reviews the additional detail and operational expectations of states during the unwinding of Medicaid continuous coverage as laid out in the SHO letter.
Safeguarding Financial Stability of Provider Risk-Bearing Organizations
Erin Taylor and Michael Bailit, Bailit Health
JoAnn Volk, Georgetown University Center on Health Insurance Reforms
An increasingly common feature of health care payment models is the transfer of financial risk from payers to providers for health care services delivered to a defined population of patients. In these “value-based payment” models, providers accept financial responsibility (i.e., liability for financial losses) should spending for most, or all, services for an attributed patient population exceed targeted levels. This financial liability is often shared with payers, and maximum risk exposure is typically capped. This issue brief explores options for states as they consider oversight of risk-bearing organizations , with a focus on states that have elected to act to protect against provider insolvency.
The State Health Policy Highlight, Risk-Bearing Organizations Oversight: State Considerations, reviews specific state considerations when overseeing risk-bearing organizations. An accompaniment to the issue brief, Case Studies: State Examples of Safeguarding Financial Stability of Provider Risk-Bearing Organizations, provides a deeper dive into approaches in four states: California, Massachusetts, New York and Texas.
State Health and Value Strategies hosted a companion webinar, Safeguarding Financial Stability of Provider Risk-Bearing Organizations, based on the issue brief that provided an overview of options for states as they consider oversight of risk-bearing organizations (RBOs) as well as a deeper dive on the Massachusetts approach.