ASHA Supports Medicaid Access Draft ASHA supports a proposed Medicaid rule—“Methods for Assuring Access to Covered Medicaid Services”—but has asked the Centers for Medicare and Medicaid Services (CMS) for explanation and expansion in five key areas. In response to the proposed rule, ASHA prepared comments that would create a standardized, transparent process for states to ... Policy Analysis
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Policy Analysis  |   August 01, 2011
ASHA Supports Medicaid Access Draft
Author Notes
  • Laurie Alban Havens, MA, CCC-SLP, director of private health plans and Medicaid advocacy, can be reached at lalbanhavens@asha.org.
    Laurie Alban Havens, MA, CCC-SLP, director of private health plans and Medicaid advocacy, can be reached at lalbanhavens@asha.org.×
Article Information
Regulatory, Legislative & Advocacy / Policy Analysis
Policy Analysis   |   August 01, 2011
ASHA Supports Medicaid Access Draft
The ASHA Leader, August 2011, Vol. 16, 3. doi:10.1044/leader.PA2.16102011.3
The ASHA Leader, August 2011, Vol. 16, 3. doi:10.1044/leader.PA2.16102011.3
ASHA supports a proposed Medicaid rule—“Methods for Assuring Access to Covered Medicaid Services”—but has asked the Centers for Medicare and Medicaid Services (CMS) for explanation and expansion in five key areas.
In response to the proposed rule, ASHA prepared comments that would create a standardized, transparent process for states to ensure that Medicaid payments are consistent with efficiency, economy, and quality of care and are sufficient to enlist enough providers to meet the care and services needs of the Medicaid-eligible population within a specific geographic area.
In the comments, ASHA supports CMS’s efforts to ensure access to quality care, but questioned the following areas of the rule.
Delivery systems: ASHA stressed the need to consider multiple delivery systems, and in particular asked CMS to include audiology and speech-language pathology telepractice as a generally accepted option for service delivery.
Managed care organizations (MCOs): The rule addresses Medicaid beneficiaries enrolled in fee-for-service programs only; ASHA asked that beneficiaries who are part of managed care organizations be included, noting that more than 70% of Medicaid enrollees are in some form of managed care, and more than half are in MCOs.
Pricing: ASHA suggested that Medicaid follow the Medicare Physician Fee Schedule (MPFS) or a percentage of the MPFS rates. Current Medicaid reimbursement rates vary widely. Reimbursement for Current Procedural Terminology (CPT, © American Medical Association) 92506 (evaluation of speech, language, voice, communication, and/or auditory processing), for example, ranges from $16 in New Jersey to $198.91 in Alaska. The suggested consideration would use the CMS geographic pricing cost index to address regional factors.
Payment method provision: CMS proposed that all covered services undergo a full review every five years. ASHA recommended more frequent review, especially if payment revision considerations are tied to that review. More frequent review would require more careful monitoring and greater accountability by state agencies for services provided. ASHA also recommended that feedback on availability and access to services be solicited from service providers, not just from beneficiaries, as CMS proposes.
Notification: ASHA requested that CMS provide adequate notification of any changes in payment to state and national professional and provider associations, so an appropriate response can be provided to any future proposed rule. ASHA also requested that, in addition to posting notification, CMS provide electronic notification to state health care and medical associations so that changes can be implemented appropriately.
The full text of the proposed regulation is at the Federal Register [PDF]. The comment letter is on ASHA’s website [PDF].
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August 2011
Volume 16, Issue 10