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.
Safety-Net Provider ACOs: Considerations for State Medicaid Purchasers
Michael Bailit and Beth Waldman, Bailit Health Purchasing LLC
With states increasingly moving to develop population-based payment arrangements with provider organizations, the critical role of safety-net providers has become a challenging consideration for states. While safety-net providers typically lack the capital, experience, and/or scale to operate as an Accountable Care Organization (ACO), their role in state Medicaid programs underscores their integral role in the implementation of a population-based payment strategy with ACOs. This issue brief, prepared by Bailit Health Purchasing, examines seven safety-net ACOs across five states to understand their origins, organization, characteristics and functions and to identify federal and state policy questions associated with their emergence. The issue brief identifies both challenges facing safety-net provider ACO aspirants and state strategies to support safety-net provider development of ACOs.