First Focus on Children submitted the following comments expressing our strong opposition to a proposed rule that would repeal the Medicaid Access Rule, harming more than 2.5 million children. The proposed rule was published in the Federal Register on July 15, 2019 (RIN 0938-AT41; HUD Docket No. CMS-2406-P2). We urge the Centers for Medicare & Medicaid Services to rescind this proposed rule.


As proposed by CMS, repealing of the Medicaid Access Rule would harm more than 2.5 million children covered by Medicaid providers that are paid on a fee-for-service basis. Under the proposed rule, state Medicaid programs would no longer have to evaluate whether enrolled children have adequate access to covered services, take corrective action if access deficiencies are identified, explain the effects on access if it proposes to reduce payments to pediatric service providers, or monitor the effects on access for kids and other Medicaid recipients if CMS approves a payment cut.

Repeal would also eliminate an important source of information for CMS as to the extent to which children and other Medicaid populations have access to needed services. Without that data set, we won’t know if kids can get the care they need and are entitled to.

Read our full comments here.