On July 14, the National MLTSS Health Plan Association submitted comments on the “Preserving Medicaid Funding for Vulnerable Population – Closing a Health Care-Related Tax Loophole” proposed rule. Per the Association:
This rule proposes to refine how CMS evaluates whether a health care-related tax is considered “generally redistributive.”
In our comments, we noted that we appreciate CMS’ efforts to strengthen the oversight and quality of Medicaid programs but raised concerns about the timelines and administrative burden on states, as well as the potential impact on individuals receiving long term-services and supports (LTSS).
The recommendations included:
- Extending the transition period to three years for all states.
- Providing clear implementation guidance and technical assistance to states.
- Postponing finalization of the rule until further research and data analysis on provider-related taxes and impacts are conducted.
Read the full letter here.
In Pennsylvania, this rule would impact participants’ funding of approximately $1B in federal matching funds for HealthChoices, Community HealthChoices, and Behavioral HealthChoices. No immediate action is required. If you have any questions, contact Fady Sahhar.
