First Focus on Children submitted the following comment to Secretary Xavier Becerra, at the U.S. Department of Health and Human Services because the proposed Access Rule, along with the Managed Care Rule, represents much-needed steps toward improving the Medicaid program, especially for children.
Excerpt from the Comment:
We recommend that CMS add additional access standards for states with a fully fee-for-service (FFS) delivery system, or for services that are covered outside of managed care in particular states (e.g., behavioral health services). In its companion Managed Care proposed rule, CMS is proposing wait time standards, secret survey shopper requirements, and related publication requirements for certain services. We support CMS applying similar standards to services delivered via the FFS delivery system, including to assess geographic variation. Children enrolled in Medicaid have the same right to accessible services regardless of whether their states elect to deliver services via the FFS or managed care delivery system, and CMS should hold states accountable for assuring access to the same degree that CMS proposes to hold managed care organizations responsible for access.