Overview of proposed pass-through payment guidance

The Centers for Medicare and Medicaid Services (CMS) has proposed updates to Medicaid managed care pass-through payment guidance. The updates appear to simplify and streamline the approval process. New authority was also proposed to facilitate fee-for-service (FFS) transitions.

The new proposed authority would allow for transitional pass-through payments to facilitate transitions from FFS delivery systems to managed care delivery systems. This applies to new populations and also to new services carved in for populations already under managed care. CMS also proposed administrative simplifications intended to streamline or eliminate the need for prior approval.

CMS noted in the proposed rule that states are continuing to shift members and services from FFS delivery systems into managed care. Transitioning to an alternative payment structure requires a significant amount of coordination and communication between multiple shareholders, including providers, CMS, the state, and the managed care plan.

To read more about proposed updates to pass-through payments and opportunities for simplification, read this paper by Andrew Gaffner and Christine Mytelka.

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