MACPAC Releases its March 2025 Report, Part 2
- Medicaid is the largest payer for long-term services and supports (LTSS), including post-acute care, covering approximately 60% of such services in the United States
- Org leaders who service Medicaid patients must understand policymakers’ attitudes toward the program. Those attitudes may be changing with a new administration and Congress.
On Thursday, March 13th, the Medicaid and CHIP Payment and Access Commission (MACPAC) released its semi-annual report. The report included three chapters and five recommendations. Below we provide a summary of each chapter and the associated recommendations with an emphasis on applicability to home care services.
Due to the care the Alliance puts into its policy analysis and communication, our coverage of the MACPAC report is lengthier than most of our articles. Accordingly, we will split it in two to make it easier for organizational leaders to digest.
Part 1 will covered Chapter one of the MACPAC report. Part 2 will cover chapters two and three.
Chapter 2: Timely Access to HCBS
In this chapter, MACPAC outlines the various issues that lead to delays in eligible individuals receiving HCBS, including:
- Long timelines for financial eligibility determinations due to the complex nature of requirements and verification protocols for older adults and individuals with disabilities;
- Delays due to functional eligibility assessment and verification to determine if individuals meet the clinical/functional “level of care” qualifications for HCBS; and
- Requirements to develop and implement a plan of care prior to delivery of service, which many states align with the comprehensive person-centered plan of care process.
MACPAC includes one recommendation in this chapter:
- Direct CMS to issue guidance on how states can use provisional plans of care, including policy and operational considerations, under Section 1915(c), Section 1915(i), Section 1915(k), and Section 1115 of the Social Security Act.
Provisional plans of care would be a way for states to fulfil the requirements of establishing a plan of care prior to the delivery of HCBS without delaying the delivery of services pending the comprehensive person-centered planning process. Although this option already exists and was articulated in guidance in 2000, many states are unaware of the opportunity to utilize these plans and they are underutilized as a result.
The Alliance, and its predecessor NAHC, has long expressed concerns regarding delays in accessing HCBS and the resulting negative outcomes for participants, including unnecessary hospitalizations, emergency room use, and nursing home placements. We agree with and support this recommendation; however, we believe that there are many additional changes that must be made in order to expedite the delivery of HCBS. These include:
- Establishing HCBS as a mandatory service without limits on the number of individuals in the program;
- A period of presumptive financial and functional eligibility for individuals at risk of hospitalization or nursing home placement to expedite the delivery of care; and
- Increased requirements on states to ensure access to care so that there are available providers for individuals to quickly access services in the community.
Chapter 3: Streamlining Section 1915 Authorities for HCBS
In this chapter, MACPAC outlines a wide range of authorities that states utilize to deliver HCBS and the varying requirements associated with each. The majority of states create their comprehensive HCBS programs within the framework established by sections 1915(c), 1915(i), and/or 1115 of the Social Security Act; however, there are a wide range of other statutory authorities used to establish HCBS around the country. Though this chapter’s discussion provides a comprehensive discussion of the complexities introduced by the variety of requirements and options within the various statutory sections, MACPAC only makes one recommendation relatively minor in this section:
- To reduce administrative burden for states and the federal government, Congress should amend Section 1915(c)(3) and Section 1915(i)(7)(C) of the Social Security Act to increase the renewal period for HCBS programs operating under Section 1915(c) waivers and Section 1915(i) state plan amendments from 5 years to 10 years.
The Alliance supports this requirement as we believe it would provide more predictable and continuous operations of HCBS around the country. However, as with the prior HCBS recommendation in Chapter 2, we believe that there are ample opportunities to improve and streamline the delivery of HCBS. We encourage MACPAC, CMS, and Congress to think more broadly and comprehensively about policy changes that could improve the delivery of care. Specifically, we believe that Congress should create a unified, streamlined Medicaid HCBS benefit that provides consistency within and across states. The benefit should have a core set of mandatory services with the option to include additional services. The program should include federal minimum standards of quality and access regardless of whether the state uses fee-for-service or managed care. States should be provided with enhanced Federal matching funds for both administration and services within this benefit.
The full MACPAC March Report is available online HERE.
Please see the Alliance analysis of chapter one of the MACPAC report HERE.
