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MESC 2026 Highlights: Medicaid Modernization, AI, Eligibility, and Program Integrity

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Key Insights from the 2026 MESC Conference and What They Mean for Your Organization 

State Medicaid agencies and partner organizations are facing one of the most consequential periods of operational change in more than a decade. Those challenges were a central focus of the 2026 Medicaid Enterprise Systems Conference (MESC), August 17-20, 2026, in Portland, OR, where state, federal, and industry leaders discussed how technology, data, and operational modernization are becoming essential tools for implementing policy change. 

During the conference, leaders of Health Management Associates (HMA) and HealthTech Solutions, an HMA company, reinforced a consistent theme: We have moved beyond the era when Medicaid enterprise systems modernization simply meant replacing aging technology. Instead, states are building the infrastructure needed to manage continuous policy evolution, support more sophisticated program integrity efforts, adapt to changing eligibility requirements, and provide the financial and operational visibility necessary to navigate an increasingly complex Medicaid environment. That direction is also reflected in recent Medicaid Enterprise Systems IT Standards Request for Information that the Centers for Medicare & Medicaid Services (CMS) issued to gather stakeholder input on how to advance a more standardized, interoperable, and cost-effective MES ecosystem. 

What We Learned at MESC 

Modernization Is Becoming an Ongoing Operating Capability 

Medicaid modernization is moving beyond the replacement of legacy systems. States are building the capabilities needed to manage continuous change. That work includes stronger governance through better data and more disciplined implementation practices; clearer ownership for decisions, risks, dependencies, and outcomes; and the development of cross-functional teams. Policy, operations, technology, finance, communications, and program leadership must work together from the beginning. 

What it means for states and partners
Modernization programs need a clear operating model that defines decision rights, measures of success, implementation responsibilities, and long-term support. Partners should help build state capability instead of focusing only on system delivery. 

Modularity Now Means Managing the Connections Between Systems 

Modularity can give states more flexibility, support specialized solutions, and reduce dependence on one large platform. Modularity, however, also creates more connections and business relationships that must be managed. A modular environment involves multiple vendors, systems, interfaces, data flows, release schedules, and support models. Because difficulties can arise when these elements are disconnected, MESC sessions emphasized the need for enterprise integration and coordination. States must manage testing, release planning, architecture, data contracts, vendor handoffs, and incident resolution. 

What it means for states and partners
Modularity requires more than modular procurement. States need an enterprise layer that manages the relationships between components. Partners should understand how their work affects the broader Medicaid ecosystem. 

Federal Requirements Are Shaping the Modernization Agenda 

CMS and other federal requirements continue to influence state priorities. Certification remains important, along with federal reporting, data quality, security, interoperability, and program integrity. The conference also reflected growing pressure to prevent fraud, waste, and abuse earlier in the Medicaid life cycle. States are strengthening provider enrollment, referral intake, payment controls, analytics, and audit preparation. These efforts move program integrity closer to the front door. The goal is to identify risk before it becomes a payment error or an investigation. 

What it means for states and partners
Compliance and program integrity should be part of solution design from the beginning. States and partners should build evidence, controls, testing, and monitoring into normal operations. These activities should not be postponed until certification or an audit is approaching. 

Eligibility Changes Require New Data and Operational Models 

Changes to Medicaid eligibility are creating new demands for states. Workforce and community engagement requirements are one example. States may also need enhanced verification, new exemption processes, shorter response timelines, and stronger outreach. 

These changes extend beyond eligibility systems. They shape how states communicate with members, support contact centers and caseworkers, manage appeals, connect data sources, and help people understand what they need to do to maintain coverage. MESC sessions underscored the value of listening to stakeholders and explored how health information exchange data and other sources could support exemption decisions and reduce preventable coverage loss. 

What this means for states and partners
Eligibility modernization must connect policy to daily operations. States need reliable data and clear workflows. They also need ways to explain changes and track outreach. Partners can translate policy into decision logic, test cases, notices, training, and operational procedures. 

AI Means Governed Support for Real Medicaid Work 

AI was a major topic of discussion at MESC. The strongest examples involved practical work rather than general experimentation. States are exploring AI for policy questions, quality assurance, document review, contact center support, knowledge management, and program integrity. These use cases can reduce administrative burden and help staff manage complex workloads. Conference speakers clarified that AI is no substitute for reliable governance structures. States need reliable content, security controls, privacy protections, human review, workforce training, and performance monitoring. 

What this means for states and partners
AI adoption should begin with a specific business problem. States should define who is accountable for the outcome and how the tool will be monitored. Partners can support use case selection, governance, procurement, testing, implementation, and workforce adoption. 

How HMA Can Help 

MESC 2026 reinforced the argument that Medicaid modernization is no longer a discrete technology project. States and their partners are responding to federal requirements, modular system complexity, eligibility changes, AI adoption, and heightened program integrity expectations at the same time. 

HMA and HealthTech Solutions help organizations turn that complexity into an actionable modernization strategy. Our teams bring together Medicaid policy expertise, operational experience, technology strategy, procurement support, compliance knowledge, and implementation discipline so clients can make better decisions and execute with confidence. 

We support organizations in assessing current systems and capability gaps, prioritizing technology investments, translating policy into operational and technical requirements, managing vendor selection and procurement, strengthening compliance and program integrity, and adopting AI in ways that are effectively governed, practical, and aligned with Medicaid business needs. 

Contact HMA experts to get your questions answered. 

Federal and State Medicaid Leaders and VA Assistant Secretary to Discuss Public Healthcare Transformation at HMA Conference

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Health Management Associates (HMA) is pleased to announce that Caprice Knapp, PhD, Principal Deputy for the Center for Medicaid & CHIP Services, will participate in two sessions at HMA’s US Healthcare 2026: Signals, Signs & Flashing Lights conference, October 5-7, 2026. in New Orleans, LA. As states, plans, providers, and community partners prepare for a new era in Medicaid and other public healthcare programs, these conversations will focus on practical solutions, implementation realities, and the partnerships needed to move from policy change to sustainable results. 

State Medicaid and CHIP Strategies for Applied Behavior Analysis and Autism Services 

As the prevalence of autism has increased, state investments in Applied Behavior Analysis (ABA) and related services have grown substantially. This preconference session will examine federal guidance and state strategies for supporting appropriate, high-quality care for children with autism while helping programs strengthen oversight, access, and service delivery. 

Medicaid Policy Changes and Their Ripple Effects Across Healthcare 

Changes in Medicaid policy and financing will not stay confined to Medicaid. Coverage churn across Medicaid, the Affordable Care Act (ACA) Marketplace, and employer-sponsored insurance can reshape risk pools, influence plan participation, increase provider financial exposure, and leave more people uninsured. This session will bring federal and state leaders together to discuss how Medicaid agencies and their partners are responding, where collaboration is most needed, and what strategies will be needed to navigate the next phase of public healthcare transformation. 

The following current and former Medicaid directors will join Dr. Knapp: 

  • Ann Jensen, Administrator, Nevada Medicaid Nevada Health Authority 
  • Cheryl J. Roberts, JD, Senior Advisor; Former Medicaid Director, Virginia Department of Medical Assistance Services 
  • Ryan Schwarz, MD, MBA, Medicaid Director & Assistant Secretary for MassHealth, Massachusetts Executive Office of Health & Human Services 
  • Scott Partika, Director, Ohio Department of Medicaid 

VA Community Care and NextGen Healthcare Innovation for Veterans 

As the nation’s largest integrated health system serving military veterans, the VA is working with health plans, providers, health systems, technology firms, and other innovators to bring effective solutions from across the healthcare marketplace to people who have served our nation. Approximately 42 percent of the healthcare services that veterans receive today is delivered through the contracted Community Care program, and that share is expected to grow. Assistant Secretary Richard F. Topping will discuss the VA’s vision for the future of Community Care, the critical role industry partners will play, and how the VA intends to learn from the field, adopt proven practices, leverage emerging technologies, and foster innovation that improves access, quality, and outcomes for veterans.

As Medicaid, VA Community Care, and other public healthcare programs enter a period of significant change, HMA’s conference will focus on the partnerships, operational strategies, and solutions needed to move from policy to implementation.

Register today to join leaders working through the decisions that will shape the next phase of public healthcare. 

September 2, 2026

Federal and State Medicaid Leaders and VA Assistant Secretary to Discuss Public Healthcare Transformation at HMA Conference

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Closing the Care Continuity Gap in Substance Use Disorder

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An actuarial view of $569 million in ACA marketplace SUD spending

Today, August 31, 2026, is International Overdose Awareness Day—a time to remember the lives lost to overdose, to support people affected by substance use, and to advance action that saves lives. In recognition of this day, Sober Sidekick and Wakely Consulting Group, an HMA Company, are releasing this new report to help strengthen the continuum of substance use disorder (SUD) care.

Health plans spend far more on acute stabilization and short-cycle services than on services that support sustained recovery, according to a joint analysis by Sober Sidekick and Wakely Consulting Group, an HMA Company.

The brief examines $569 million in allowed costs for approximately 150,000 Affordable Care Act (ACA) Marketplace members with a primary SUD diagnosis during benefit year 2023.

Key findings

  • For every $1 spent on sustained recovery services, $3.64 was spent on acute stabilization and short-cycle services.
  • Acute stabilization and short-cycle care represented 51.5% of analyzed spending, or approximately $293 million.
  • Sustained recovery services represented 14.1% of analyzed spending, or approximately $80.4 million.
  • Emergency department (ED) utilization accounted for the largest single concentration of spending, totaling $127.9 million across six billing codes.
  • No sustained recovery service appeared among the 11 highest spend billing codes; the first appeared at rank 12.
  • Medically assisted treatment (MAT) accounted for approximately 1.6% of SUD-primary spending in the dataset.
  • Members using acute stabilization services averaged $5,577 in annual allowed costs, compared with $3,506 for members using sustained recovery services.
  • Redirecting a portion of spending toward recovery sustaining services represents an estimated opportunity of approximately $2,071 per member.

The $2,071 figure is a planning estimate, not a guaranteed savings projection. Results are sensitive to local market conditions, member characteristics, benefit design, provider capacity, and claims experience.

Why this matters

EDs, detoxification, ambulance services, and residential care are often clinically necessary and can be lifesaving. The analysis does not recommend reducing access to these services.

Instead, it identifies a care continuity gap—the period before and after an acute event when members may not receive timely follow-up, MAT treatment, case management, psychotherapy, or ongoing peer support.

Closing that gap may help health plans move from episodic crisis response toward a more continuous model of SUD care.

What this brief examines

Wakely actuaries and HMA SUD clinical experts classified 200 Healthcare Common Procedure Coding System codes according to their relationship to sustained recovery. The framework considered:

  • Strength of clinical evidence for SUD outcomes
  • Cost-effectiveness reported in the literature
  • Whether a service addresses upstream prevention or downstream consequence
  • Contribution to long-term, stable recovery

The analysis grouped services into highest-value, high-value, mid-value, low-value, and lowest-value tiers. Mid-value services represented 34.4% of analyzed spending and were excluded from the headline 3.64:1 ratio because their relationship to long-term recovery was considered context dependent.

Implications for health plans

The findings point to several opportunities for payer and provider organizations:

  1. Identify members at key inflection points, including ED visits, detoxification, residential discharge, and missed follow-up
  2. Improve initiation and retention of medication-assisted treatment
  3. Connect members with peer support and case management between clinical appointments
  4. Monitor engagement patterns to identify potential disengagement earlier
  5. Explore value-based arrangements tied to treatment initiation, treatment engagement, post-ED follow-up, post-discharge follow-up, and pharmacotherapy for opioid use disorder

Frequently asked questions

What is the care continuity gap in SUD?

The care continuity gap is the period between acute stabilization and ongoing recovery support. It can occur after an ED visit, detoxification episode, residential discharge, or between monthly outpatient appointments.

What is the 3.64:1 finding?

For every $1 of analyzed SUD-primary spending on sustained recovery services, $3.64 was spent on acute stabilization and short-cycle services. The ratio compares low- and lowest-value tiers with high- and highest-value tiers; mid-value services were excluded.

What population was studied?

The analysis examined approximately 150,000 ACA marketplace lives with a primary SUD diagnosis during benefit year 2023, using $569 million in allowed costs from the Wakely ACA Database.

Does the report recommend reducing emergency or detoxification care?

No. Acute services can be clinically necessary and lifesaving. The report focuses on improving the connection between crisis services and sustained recovery.

Is the estimated $2,071 opportunity guaranteed savings?

No. It is a planning estimate based on observed differences in annual allowed costs between members using acute stabilization services and those using sustained recovery services. Actual results will vary by market and population.

Who produced the analysis?

The brief was produced jointly by Sober Sidekick and Wakely Consulting Group, an HMA Company. Wakely actuaries and HMA SUD clinical experts developed the recovery value classification framework.

Download Closing the Care Continuity Gap in SUD: An Actuarial View of $569M in ACA Marketplace SUD Spending to review the methodology, service classifications, claims distribution, implications for value-based payment, supporting evidence, and modeling disclosures.

Rural Health Transformation Program: The Window to Build Sustainable Change Is Now

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The Rural Health Transformation Program (RHTP) is entering a critical implementation phase. As states begin deploying historic federal investments in rural healthcare, attention is shifting from grant awards to execution, performance measurement, and sustainability. Recent Centers for Medicare & Medicaid Services (CMS) approvals of additional state RHTP initiatives, coupled with upcoming reporting requirements and future funding determinations, are heightening the focus on how states, providers, technology companies, and community organizations will demonstrate progress and long-term value. 

This article examines emerging themes in RHTP implementation, including the growing emphasis on chronic disease prevention, technology-enabled care delivery, performance measurement, and sustainability planning. Health Management Associates’s (HMA) multidisciplinary teams also are available to support organizations seeking to maximize the long-term value of RHTP investments beyond the initial federal funding period.

Common Priorities Emerging in State Rural Health Transformation Program Plans 

State RHTP strategies vary considerably; however, state applications share several priorities aligned with CMS’s funding priorities. Technology modernization, telehealth, workforce development, chronic disease management, behavioral health, maternal health, and care coordination appear throughout state proposals. Through its work with states, providers, and rural communities, Health Management Associates (HMA) has identified another common thread across applications: rural health challenges are deeply interconnected.  

Providers struggling with workforce shortages are often serving populations with higher rates of chronic disease. Communities facing limited specialty access frequently experience transportation barriers and gaps in digital connectivity. Behavioral health needs intersect with physical health conditions, maternal health outcomes, and emergency department utilization. States are responding by increasing their focus on and pursuit of broader transformation strategies. 

During a recent HMA webinar, RHTP Beyond the Grant Approval: Building Sustainable Rural Transformationspeakers highlighted one of the most important directional lessons emerging from early RHTP implementation: technology, workforce, access, care delivery, and prevention strategies must be designed as mutually reinforcing investments and not as siloed initiatives. 

Chronic Disease Prevention and Management Is Central to Rural Health Transformation 

Our work with states and their RHTP partners indicates that chronic disease prevention, monitoring, and management have become a central organizing principle for many RHTP investments. Technology modernization, telehealth expansion, workforce initiatives, behavioral health integration, and community-based care models are frequently being positioned as complementary strategies to improve population health and address the conditions that drive preventable morbidity, mortality, and healthcare costs in rural communities. This includes ensuring rural residents receive care earlier, stay connected and engaged in their care longer, and avoid preventable deterioration in health status. 

As HMA experts discussed during the recent webinar, this represents an important shift. Historically, many healthcare systems have been structured around treating disease after complications emerge. RHTP creates an opportunity to invest in more effective models, including those that can identify risk sooner, improve follow-up with patients, and strengthen connections between patients and care teams. 

Telehealth, Data Platforms, and AI Support in Rural Health Transformation 

Technology appears throughout nearly every state strategy and is often viewed as one of the most visible components of RHTP. HMA webinar speakers emphasized that technology is a vital enabling capability in RHTP initiatives.

Technology alone is unlikely to produce meaningful transformation. 

HMA is working with states and their partners on strategic approaches to technology adoption. For example, states, providers, care teams, and patients should consider technology initiatives that can strengthen care models, extend workforce capacity, improve coordination and collaboration in support of population health, and generate actionable insights. 

Sustainability Planning Must Begin Early in the Rural Health Transformation Program  

Every state and RHTP participant understands that this federal funding is temporary. The urgent challenge is to identify, early and explicitly, which initiatives can produce enough value to warrant ongoing support after the funding period concludes. 

While some states awarded the first year of RHTP funding quickly, many of these awards may serve as a bridge while states establish the structures and policies needed to support long-term RHTP initiatives. CMS’s reporting and ongoing evaluation of RHTP programs will require states to embed sustainability into program design, governance, measurement, financing, and partnerships from the outset. 

States will need to provide RHTP participants with clear baselines and direction on meaningful outcomes. It also requires thinking beyond grant budgets to identify long-term operational and financial models capable of supporting ongoing services. 

What States, Providers, and Technology Partners Should Do Next 

The window for shaping long-term RHTP success is open now. State and local government and partner organizations have an opportunity to move beyond individual projects and build integrated strategies.  

HMA’s multidisciplinary teams support program design, implementation planning, data strategy, technology modernization, performance measurement, governance, financing strategy, partnership development, and sustainability planning. As states and RHTP participants make decisions regarding governance, technology, data strategy, care models, and performance measurement, HMA can help ensure decisions and investments are optimized to make the progress needed to secure future funding and sustain transformation beyond the grant period.  

Modernizing and Streamlining Health Plan Prior Authorization

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In this webinar, leaders from HMA and NTT DATA will explore the common sources of friction and inefficiency in prior authorization (PA) processes and discuss how modern technology, including artificial intelligence (AI), can help streamline PA operations, improve compliance, and enhance the experiences for health plans, providers, and members. Attendees will gain insights into the evolving regulatory landscape, the root causes of PA administrative burden, and practical strategies for leveraging IT modernization to create more efficient, transparent, and effective prior authorization workflows.

Explore how AI and other IT modernization strategies can reduce PA administrative burden, improve compliance, and enhance the experiences for health plans, providers, and members.

Learning Objectives:
Identify and discuss the root causes of friction and inefficiency in current prior authorization processes and systems.

Review recent legal and regulatory developments that are shaping the health plan prior authorization function.

Explore how AI and other IT modernization strategies can reduce administrative burden, improve compliance, and enhance the experience for health plans, providers, and members.

Featured Speakers:

Sezin Palmer, Managing Director, AI Industry Solutions Lead, NTT Data

Navesh Kandiyil, MD, MBA, FACHE, Transformative Executive, NTT Data

CMS’s Proposed Provider Tax Rule Could Reshape Medicaid Financing

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The Centers for Medicare & Medicaid Services (CMS) has proposed significant changes to how Medicaid provider taxes are structured, reported, and monitored. Issued in response to the Working Families Tax Cut Act (WFTCA), the proposed rule would affect provider tax grandfathering, hold harmless thresholds, reporting requirements, and permissible tax classes, with important implications for states, Medicaid agencies, health plans, providers, and other healthcare stakeholders.

This issue brief from HMA breaks down the proposal into practical, actionable insights. It highlights what is changing, what remains uncertain, and the operational and financial considerations organizations should evaluate as CMS moves toward a final rule.


Executive Summary

CMS’s July 2026 proposed rule introduces sweeping changes to the administration of Medicaid provider taxes, implementing provisions required under the Working Families Tax Cut Act (WFTCA). Among the most significant proposals are revised standards for determining which provider taxes qualify for grandfathering, new methodologies for calculating grandfathered tax rate thresholds, expanded state reporting requirements, elimination of the “75/75” indirect hold harmless test, and creation of a new permissible tax class for certain health insurers.
Many of these proposals introduce new operational requirements and leave important implementation questions unanswered. This issue brief summarizes the proposed rule and outlines the potential implications for Medicaid financing, provider tax programs, and state implementation strategies.


Key Takeaways

  • CMS proposes new standards for determining whether provider taxes qualify for grandfathering under the WFTCA.
  • States would be required to calculate grandfathered provider tax thresholds using actual tax collection and net patient revenue data.
  • The proposal establishes new one-time and ongoing quarterly reporting requirements for provider taxes.
  • CMS proposes eliminating the second prong of the 75/75 indirect hold harmless test, making applicable hold harmless thresholds the primary compliance standard.
  • A new permissible provider tax class for certain health insurers could affect future state financing strategies.
  • Several operational and policy questions remain unresolved and may be addressed through the rulemaking process.

What You’ll Learn

This issue brief provides a practical overview of the July 2026 proposed rule, including:

  • How CMS proposes to determine whether provider taxes qualify for grandfathering
  • The methodology for calculating grandfathered tax rate thresholds
  • New reporting requirements and implementation timelines for states
  • Proposed changes to the indirect hold harmless provisions
  • The potential impact of creating a new permissible tax class for health insurers
  • Operational considerations and implementation questions organizations should begin evaluating now

Frequently Asked Questions

Why did CMS issue this proposed rule?

The proposed rule implements provisions included in the Working Families Tax Cut Act (WFTCA) related to provider taxes and Medicaid financing.

Who could be affected?

The proposal has implications for state Medicaid agencies, health plans, providers, health systems, and other organizations involved in Medicaid financing and provider tax administration.

What are the biggest proposed changes?

The rule proposes changes to grandfathering requirements, provider tax threshold calculations, ongoing reporting requirements, indirect hold harmless policies, and permissible provider tax classifications.

Does the proposed rule answer every implementation question?

No. HMA identifies several operational questions and policy issues that remain unresolved, including reporting methodologies, implementation timing, compliance processes, and how certain provisions may be applied in practice.

Why It Matters

Provider taxes play an important role in Medicaid financing, and the proposed rule would significantly change how states establish, administer, and monitor these programs. New reporting requirements, revised grandfathering standards, and phased changes to hold harmless thresholds could affect state financing strategies, Medicaid payments, compliance activities, and long-term budget planning.
Organizations that understand the proposal early will be better positioned to evaluate potential impacts, prepare for implementation, and participate in the rulemaking process.


Why HMA’s Analysis Matters

The proposed rule is lengthy, technical, and operationally complex. HMA’s experts reviewed the regulation and distilled its most significant provisions into a concise issue brief designed for healthcare leaders.

Beyond summarizing the proposal, HMA identifies areas where implementation may present challenges, highlights operational considerations, and outlines policy questions that remain unanswered. This practical perspective helps organizations understand not only what CMS is proposing, but also what it could mean in practice.

Need Assistance?

Changes to Medicaid provider tax policy can have significant implications for financing, compliance, and long-term strategic planning.

HMA works with state Medicaid agencies, health plans, providers, and other healthcare organizations to assess the impact of federal policy changes, evaluate Medicaid financing strategies, and prepare for evolving regulatory requirements. If your organization is assessing how the proposed provider tax rule could affect its operations or financing approach, our experts can help.

Connecting the Dots: Medicaid Program Integrity Enters a New Era of Strategy and Operational Readiness

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There is no shortage of news, federal activity, and operational urgency concerning fraud, waste, and abuse (FWA) in healthcare. Across Medicare, Medicaid, the Affordable Care Act Marketplaces, and other federally funded health programs, the executive branch is advancing a more aggressive program integrity agenda. The US Department of Health and Human Services (HHS), including the Centers for Medicare & Medicaid Services (CMS) and HHS Office of Inspector General, as well as the US Department of Justice, are placing greater emphasis on payment accuracy, provider and vendor oversight, data-driven detection, and defensible compliance processes. 

As scrutiny intensifies, organizations across the healthcare ecosystem are challenged to move beyond traditional audit and recovery activities toward a more proactive, enterprise-wide approach to managing risk and preventing FWA. Although these trends affect all healthcare stakeholders, the implications for Medicaid are particularly significant given the program’s scale, complexity, and reliance on partnerships among state agencies, managed care organizations, providers, and technology vendors. 

To better understand how organizations should respond, Jennifer Colamonico connected with Clint Eisenhower, Regional Director at Health Management Associates (HMA), and Jennifer Bridgeforth, Associate Principal at HMA. The discussion below incorporates insights from HMA colleagues Christine Rein, Amber Swartzell, and Elizabeth Linville, who joined HMA’s August 12, 2026, webinar on how new program integrity expectations are affecting Medicaid payment, operations, and compliance strategies.

Jennifer Colamonico: We hear a lot lately about heightened scrutiny and program integrity. What’s fundamentally different about this moment from what Medicaid leaders and their organizations have experienced in the past?

Clint Eisenhower: The biggest shift is that program integrity can no longer be viewed as a narrow compliance function. What we are seeing now is a move toward enterprise accountability—and we are really at the outset of this journey. Program integrity touches finance, operations, eligibility, screening, compliance, provider oversight, analytics, clinical teams, procurement, technology, and leadership decision-making. A provider issue can become a payment issue. A data gap can become an audit issue. A documentation weakness can become a compliance issue. The organizations that are best positioned are the ones that understand how those functions connect and can demonstrate that they are managing risk in a coordinated, evidence-based way. 

From a leadership standpoint, leaders of Medicaid organizations can’t simply ask whether they have a program integrity function. We know—and federal and state regulators know—that most organizations do. Instead, leaders need to ask whether that function is designed to withstand increasing scrutiny while it also helps the organization manage risk, support stronger operational performance, and continue to serve Medicaid beneficiaries effectively. 

Q: Many organizations are trying to figure out whether this is just another enforcement cycle or something more significant. How are you advising clients to think about the current level of federal scrutiny? 

Eisenhower: Every organization should be asking where its greatest vulnerabilities are—whether its controls, oversight processes, policies or operational capabilities may not be sufficient to address them. From there, leaders can prioritize what should be addressed now and what can be phased in. 

We’ve worked with agencies and organizations first on the objective assessment of their risk and moved to translate the findings into operational change, which may include developing roadmaps, updated workflows, and& stronger policies, among other actions.

Q: There’s a lot of discussion about moving beyond the traditional pay-and-chase model, but what does a program integrity-first approach look like in practice? 

Jennifer Bridgeforth:HMA is working with many state leaders and healthcare organizations that are navigating significant changes across Medicaid financing, eligibility and enrollment systems, and program administration. At the same time, new federal policy and budget constraints are prompting many states to rethink how services are delivered, managed, and financed. Whether a state is redesigning benefits, implementing new eligibility processes, restructuring payment approaches, or pursuing broader delivery system reforms, program integrity considerations need to be embedded into those decisions from day one. 

That includes documentation requirements, monitoring protocols, data validation, and accountability structures built into the program design. 

It also means aligning oversight efforts with emerging federal and state priorities. We are seeing increased attention on areas such as nonemergency medical transportation, applied behavior analysis, personal care services, durable medical equipment, and behavioral health services, as well as techniques such as evaluation and management coding, and identifying high-volume billing patterns. Medicaid leaders need to design programs and workflows that identify risks earlier, support appropriate access to care, and create feedback loops that strengthen operations over time, reducing reliance on a traditional pay-and-chase approach. 

Q: One challenge we hear about frequently is how to strengthen oversight without creating barriers to care. How can organizations strike that balance, particularly in areas like behavioral health and applied behavior analysis (ABA), where access is already strained? 

Bridgeforth: That balance is critical. Many of the areas under scrutiny are also in which there is tremendous demand and, in some markets, a shortage of providers. ABA and behavioral health are good examples. The answer cannot be to discourage appropriate access. Instead, organizations need stronger documentation, clearer policies, better training, and a shared understanding of what compliant billing and service delivery look like. 

Provider education is one of the most important tools. When providers are asked to document more or differently, it can feel like administrative burden. Education has to explain not only what the requirements are, but why they matter. 

Eisenhower: Health plans and providers have a strategic opportunity here. States still need partners to help achieve access goals and improve outcomes. Plans, providers, and vendors that can demonstrate strong program integrity policies and effective oversight can position themselves as trusted partners. They help states pursue access and quality goals with greater confidence that those initiatives will not create unnecessary compliance exposure. 

Q: Organizations are investing heavily in analytics and AI capabilities. Where do you see the greatest opportunity for these tools to strengthen program integrity efforts? 

Bridgeforth: Advanced analytics and AI are becoming increasingly important for detection and prevention. Real-time monitoring, claims pattern analysis, and predictive tools can help organizations identify risk earlier and take action before issues become larger findings or recoveries. But technology is valuable only if the organization has the governance, workflows, documentation, and case management processes to act on the data that the tools identify. 

Cross-program compliance is also important. Many organizations operate across Medicaid, Medicare, Marketplace, commercial, and other public programs. When program integrity is approached at the enterprise level, improvements in one area can strengthen compliance across multiple product lines or programs. 

Q: You’ve worked with states and healthcare organizations at very different stages of maturity. What are some of the most common gaps or challenges you’re helping clients address today? 

Bridgeforth:We’ve worked with organizations atvery different stages of maturity.For example, we supported an organizational assessment and gap analysis that helped a client identify major opportunities across its program integrity function. The team developed a roadmap organized across seven FWA pillars, identified 52 enhancement opportunities, translated those into 184 key actions, and developed 116 success measures so leadership could monitor progress over time. 

HMA and HealthTech Solutions, an HMA Company, also supported a statewide implementation that included electronic visit verification improvements, prepayment analytics, post-payment analytics, and modernization of claims review processes. The effort the state move from manual, reactive processes toward a more proactive model, with insights from post-payment analytics informing prepayment edits that could be updated in weeks rather than months. 

Q: If you’re a Medicaid leader looking ahead to the next 12 to 24 months, what should be at the top of your program integrity agenda? 

Eisenhower: Many of the steps that reduce program integrity risk are the same steps that help organizations perform better: stronger governance, better data, clearer accountability, more consistent workflows, improved provider relationships, and effective monitoring. The upside is not only avoiding findings or reducing audit exposure. It is also ensuring Medicaid dollars are directed to the right beneficiaries, the right services, the right providers, and the right outcomes. 

How HMA Can Help 

HMA helps states, health plans, providers, and healthcare organizations assess program integrity risk, strengthen governance and compliance infrastructure, design and implement payment integrity strategies, support provider education, modernize analytics and monitoring, and translate findings into measurable operational improvements. HMA can meet organizations where they are, whether they need a targeted assessment, a phased roadmap, implementation support, data analytics support, or enterprise-wide program integrity transformation. 

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SFY 2027 Budgets Signal How States Are Responding to Medicaid and SNAP Funding Provisions in the WFTCA

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State fiscal year (SFY) 2027 budgets provide insights into how states are responding to the Medicaid and Supplemental Nutrition Assistance Program (SNAP) funding and operational changes included in the 2025 budget reconciliation legislation, P.L. 119-21, the Working Families Tax Cut Act (WFTCA). Many of the law’s most significant changes will phase in, with full implementation set for 2029. Nonetheless, states are already adjusting their budgets, operational infrastructures, eligibility requirements, and financial strategies to address WFTCA’s new administrative requirements, reductions in federal Medicaid funding, and increased SNAP cost sharing responsibilities, among other reforms.  

In its newly updated report, Fiscal Year 2027 Enacted State Budget Overview (subscriber access required), Health Management Associates Information Services (HMAIS), examined state Medicaid agency funding and budget provisions that signal how states are preparing for WFTCA implementation. As of July 31, 2026, all states except South Carolina had enacted their SFY 2027 budgets, and many states that enacted two-year spending plans in 2025 have now approved supplemental budgets. Some states are investing in staffing, eligibility systems, compliance activities, and other infrastructure to maintain coverage and services wherever possible, while others are identifying reductions or alternative funding strategies as they look ahead to more limited federal funding and future budget tradeoffs. 

Following is a snapshot of the key trends and state responses to WFTCA policies, which the full report covers in more detail. 

Medicaid and SNAP Policy Changes Shaping State FY 2027 Budgets 

Major WFTCA provisions affecting state budgets include work/community engagement requirements and more frequent eligibility checks for expansion beneficiaries, an increased state share of SNAP administrative costs, and restrictions on provider taxes and state directed payments. 

Medicaid Community Engagement Requirements Drive New State Investments. States that expanded Medicaid eligibility through the Affordable Care Act (ACA) must implement an 80-hour per month community engagement/work requirement for expansion populations by January 1, 2027. These enrollees will also be subject to six-month eligibility reviews. 

In anticipation of significant administrative demands, states allocated funding for more staff, IT enhancements, provider and community education, as well as public education to assist individuals subject to the new requirements. States already had been working to meet this requirement before the Centers for Medicare & Medicaid Services (CMS) released the Medicaid Community Engagement Requirement for Certain Individuals Interim Final Rule (CMS-2454-IFC) on June 1, 2026. They may need to adjust their funding requests and implementation strategies to align with the new federal mandates. Examples of state responses include: 

  • Illinois allocated $55 million to the Department of Human Services to hire 450 additional staff and update eligibility determination systems to implement new eligibility and work requirements for Medicaid and SNAP. 
  • Kentucky’s biennial budget includes $35 million in SFY 2027 and $11 million in SFY 2028 to implement Medicaid work and community engagement requirements and other related needs. 
  • Maine’s supplemental SFY 2025–27 budget includes funding to establish 35 eligibility specialist positions as well as other workers to implement work requirements. 

States Budget for Higher SNAP Administrative Costs and Error Rate Penalties. States are now responsible for 75% of SNAP administrative costs, up from 50% previously. Beginning in federal fiscal year 2028, the WFTCA imposes a cost sharing requirement on states that have a SNAP payment error rate of more than 6%. In response, many states included funding or budget language to address these new fiscal and administrative responsibilities. Examples include: 

  • Arizona is allocating $31.8 million for the Department of Economic Security to cover the larger state share of administrative costs, as well as $10.8 million and 88 full-time equivalent (FTE) positions to reduce the SNAP error rate. 
  • California’s Department of Social Services is set to receive a $30.6 million general fund increase to account for the increase state share of administrative expenses, a nearly $8 million total increase for CalFresh staffing for WFTCA and federal changes and a $4.8 million total increase for enhanced monitoring of CalFresh to meet new error rate requirements. 
  • Florida is setting aside $4 million for the Department of Children and Families to procure a vendor to help reduce the SNAP error rate. 
  • Iowa included an increase of $8.7 million for the increased state share of SNAP administrative costs. 
  • Applying a slightly different approach to the error rate, Alabama’s budget requires the Department of Human Resources to develop a plan that will modify SNAP benefits or eligibility as necessary to cover any penalty imposed on the state in SFY 2028. 

States Assess the Impact of Federal Restrictions on Medicaid Financing Tools. The WFTCA freezes current provider tax programs, bars new ones, and requires Medicaid expansion states to phase down the minimum allowable tax rate from 6% to 3.5% by 2032. It also caps state directed payments at 100% of Medicare rates for expansion states and 110% for non-expansion states. Grandfathered payment arrangements will be phased down by 10% annually beginning in 2028. 

While this provision will not fully impact states until the next fiscal year, some states are already alerting policymakers and Medicaid organizations that the change will significantly affect their approach to financing the state share of Medicaid costs. States signaling the challenges ahead include: 

  • New York reported that its assessment tax on managed care organizations (MCOs) is noncompliant with WFTCA. 
  • California’s MCO tax is also noncompliant and will expire December 31, 2026. The state’s budget does include an WFTCA-compliant tax that will generate $575 million in SFY 2027, $2.3 billion in SFYs 2028 and 2029, and $1.7 billion in SFY 2030. 
  • Although West Virginia’s final budget includes $877 million from Health Care Provider Tax collections to cover medical services and associated administrative costs, this amount is $46.1 million more than was included in Gov. Patrick Morrisey’s proposed budget. The governor’s proposed budget highlighted how the state will be able to rely less on funds accrued from this tax because of the WFTCA’s limits on provider taxes. 

States Increase Investments in Program Integrity and Fraud Prevention 

Multiple state budgets also account for the federal government’s crackdown on fraud, waste, and abuse (FWA) in Medicaid and other public benefit programs. Missouri’s Department of Social Services budget includes $17.9 million for the Missouri Medicaid Audit and Compliance Unit to design, implement, maintain, and operate a Medicaid provider enrollment system; $7 million for a case management, provider enrollment, and fraud detection system; and $6.7 million to expand efforts to eliminate fraud through proactive measures using data analytics. 

Florida allocated $10.8 million total to combat public assistance fraud, including $2 million in nonrecurring state funds for the Department of Financial Services to competitively procure and implement a public assistance fraud software solution to prevent, detect, and investigate SNAP fraud. 

In addition, Rhode Island’s budget establishes an Office of the Inspector General to combat FWA of public funds; Arizona is increasing staff for its Medicaid Fraud Control Unit by four FTE positions; and Colorado included funds to improve the state’s provider directory and conduct a pediatric behavioral therapy audit. 

WFTCA Could Reshape Medicaid Financing, Enrollment, and Market Strategy  

The WFTCA will reshape Medicaid financing, eligibility, enrollment, and program operations over the next several years, requiring states, health plans, providers, and other stakeholders to adapt to an evolving policy and market landscape. Although many provisions phase in through 2029, SFY 2027 budgets demonstrate that implementation is already underway. New York, for example, projects annual federal funding for Medicaid and the Essential Plan will decline from $77.5 billion in SFY 2027 to $68.5 billion in SFY 2030—a nearly $10 billion annual reduction. California estimates federal community engagement requirements could reduce program costs by $357.6 million in SFY 2027 and approximately $9.6 billion through SFY 2029–30. 

HMA Helps Organizations Navigate Medicaid Transformation and WFTCA Implementation 

States and other stakeholders will need to continue to adapt as the full effects of WFTCA and other federal priorities take hold. Health Management Associates (HMA) brings the expertise, tools, and insights needed for stakeholders to stay on top of the rapidly changing environment. Contact HMA’s Medicaid experts to discuss how state budget and policy decisions affect your organization’s strategy, operations, and long-term positioning in this evolving healthcare landscape. 

The full report is available to HMAIS subscribers through our Medicaid competitive intelligence, strategy, and transformation tool. 

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