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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. 

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. 

Early Bird Pricing Ends August 7 for HMA’s National Conference: US Healthcare 2026: Signals, Signs & Flashing Lights

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The agenda is now live for US Healthcare 2026: Signals, Signs & Flashing Lights, the Health Management Associates (HMA) national conference, October 5-7, 2026, in New Orleans, LA. Healthcare leaders will join peers, policymakers, innovators, and industry experts to discuss the most significant trends in healthcare, including historic policy and financing changes in Medicaid, program integrity, artificial intelligence (AI), behavioral health transformation, affordability challenges, and emerging care delivery models. 

Early bird registration pricing ends August 7!

New This Year: Two Exclusive Preconference Sessions 

HMA is offering two special preconference sessions that combine our expert-led learning with valuable networking opportunities.  

Attendees will deepen their understanding of, and gain insights into, the federal policy landscape heading into the mid-term elections. This interactive session led by Leavitt Partners, an HMA company, will help attendees understand what’s coming next from Washington, DC, and explore the strategic implications for health plans, providers, state agencies, and healthcare investors. 

A preconference session, AI in Healthcare: Moving from Experimentation to Execution, will lead attendees through practical applications of AI across healthcare operations, clinical workflows, analytics, consumer engagement, and administrative efficiency. Discussion will center on topics such as governance, implementation, and risk considerations. Attendees will have the opportunity to learn from peers, share experiences, and build connections in a collegial setting before the main conference begins. 

Key Topics Shaping the Healthcare Agenda 

The 2026 agenda is intentionally reflective of the issues facing leaders who work in strategy, operations, growth, policy, innovation, quality, and community impact across healthcare sectors.  

Highlights include sessions on: 

  • The future of Medicaid financing, delivery system transformation, and state innovation 
  • Fraud, waste, abuse, and program integrity priorities across federal and state programs 
  • AI applications that are reshaping healthcare operations, care delivery, and decision-making 
  • Rural Health Transformation Programs (RHTPs) and strategies for sustainable community investment 
  • Behavioral health policy and delivery trends, including the evolving crisis care continuum 
  • Applied behavior analysis (ABA) therapy at the intersection of behavioral health, access, and oversight 
  • Life sciences innovation and its impact on payers, providers, and patients 
  • Coverage transitions, affordability challenges, and changing market dynamics 
  • Emerging opportunities for collaboration across healthcare, social services, and community-based care 

Attendees also will have opportunities to engage in HMA’s popular Coffee Conversations, during which participants can join facilitated discussions on timely topics and exchange ideas.  

Review the full agenda, secure your hotel accommodations, and take advantage of early bird savings before August 7, 2026.

Connecting the Dots: What CMS’s Proposed Rule on Provider Taxes Rule Could Mean for States, Marketplaces, and Health Insurers

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The Centers for Medicare & Medicaid Services (CMS) issued a proposed rule on July 21, 2026, to implement Section 71115 of the 2025 budget reconciliation act, P.L. 119-21, the Working Families Tax Cut (WFTCA). The proposal calls for introducing significant changes to how states finance Medicaid through healthcare-related taxes.  

Though much of the attention has focused on the proposed rule’s implications for Medicaid provider taxes, it also raises important questions for State-Based Marketplaces (SBMs), Section 1332 reinsurance programs, health insurers, and state budget officials. The comment period closes September 12, 2026, giving states and stakeholders a limited window to assess the proposal and provide feedback to CMS. 

To better understand the potential implications, Andrea Maresca spoke with Mary Goddeeris, Principal at Health Management Associates (HMA) and Medicaid financing expert; Lina Rashid, Principal at HMA and federal healthcare and Marketplace policy expert; and Zach Sherman, Managing Director for Coverage Policy and Program Design at HMA, and a national expert on ACA Marketplaces and state coverage programs.  

Q: What is CMS proposing in this rule, and why is it generating attention among state policymakers and healthcare leaders? 

Mary Goddeeris: At its core, the proposal implements Section 71115 of WFTCA, which significantly changes the federal rules governing Medicaid provider taxes. Historically, states could satisfy the federal indirect hold harmless test by using a generally applicable 6 percent threshold. The new law replaces that standard with more restrictive state- and provider-specific thresholds. For many provider taxes in Medicaid expansion states, allowable thresholds will phase down beginning in fiscal year 2028 and fall to 3.5 percent by 2032. The proposed rule implements those statutory changes.  

The statutory change has attracted a lot of attention because provider taxes are one of the primary tools states use to finance Medicaid programs. Any changes to those financing mechanisms can have a ripple effect on state budgets, provider payments, managed care financing, supplemental payment programs, and long-term Medicaid strategy. State officials and healthcare leaders are all evaluating the potential fiscal and operational implications. 

Q: The proposal is framed as a Medicaid financing rule. Why are stakeholders outside Medicaid also paying attention? 

Lina Rashid: One reason is that CMS proposes creating a new permissible provider tax class called “services of health insurers.” CMS indicates this class could include issuers offering individual market coverage, group market coverage, catastrophic plans, short-term limited duration insurance, and certain excepted benefit products (dental and vision only policies), among others. Managed care organizations would generally remain under an existing provider class. 

The proposal raises questions because many states already use insurer assessments to fund activities outside Medicaid. These assessments may support State-Based Marketplaces (SBMs), Section 1332 reinsurance programs, or other state affordability initiatives. The proposed rule seems to make these assessments subject to the same provider tax framework and hold harmless restrictions that would be applied to Medicaid financing rules. 

The proposal does not clearly answer how broadly CMS intends to interpret these provisions, especially in the cases of taxes that have no direct connection to Medicaid financing. Under a strict framework, it is possible that many states may not meet CMS’s standard, and that they may face financial consequences with respect to the Medicaid program, SBMs, or other initiatives.  

Q: How could the proposed rule affect ACA Marketplaces and Section 1332 reinsurance programs? 

Zach Sherman: The immediate challenge is the uncertainty with this proposed rule. Many SBMs and reinsurance programs rely on assessments imposed on commercial health insurers. Currently, those assessments generally support Marketplace operations, affordability programs, or reinsurance initiatives rather than Medicaid. 

CMS writes that healthcare-related taxes imposed on the new insurer class would be subject to the same hold harmless framework established in Section 71115. The proposal does not, however, clearly state whether insurer assessments used for non-Medicaid purposes would be included. Clarity on this issue is critical because many states depend on these assessments to sustain Marketplace infrastructure and affordability initiatives. 

States that already operate SBMs, states considering transition to an SBM, and states supporting reinsurance programs through insurer assessments will want to evaluate how the proposal could affect existing funding models and future flexibility, alongside impacts to Medicaid funding.

Q: For the newly established health insurer permissible class, is the applicable threshold determined by aggregating all taxes imposed on entities within the class, for example including assessments on individual market issuers and catastrophic plans, or is the threshold applied separately to distinct entities within the class? 

Rashid: If individual market issuers and catastrophic plans are both included in the same new permissible class (“services of health insurers”), then they would be aggregated across the class to measure if it meets CMS’s threshold, not separately. It would be the combined impact of individual market issuers and catastrophic plans revenue generated from the taxes imposed divided by the applicable revenue base for the health insurer class.    

Q: What are the most significant questions states should be considering right now? 

Goddeeris: States first need to understand their exposure under the Medicaid provisions themselves. Many states rely heavily on provider taxes to support Medicaid financing. They should be analyzing existing tax structures, estimating future fiscal impacts, and understanding how the phased-down thresholds could affect funding sources over time. 

State officials should also consider how this proposal intersects with other major Medicaid policy and budget pressures. States are conducting eligibility redeterminations, implementing new federal requirements, evaluating managed care financing approaches, and managing broader budget constraints. This proposed rule could become another important factor in long-term Medicaid financing decisions and potential driver for significant policy and programmatic changes. 

Q: Where should healthcare stakeholders focus their attention while the regulation is pending?  

Sherman: Stakeholders should start by assessing whether they could be directly or indirectly affected. States, Marketplaces, health plans, providers, and trade associations may all have different perspectives on implementation questions that remain unresolved. 

Rashid: Organizations also should focus on identifying areas where they need additional clarification. In our review, some of the most significant questions involve the scope of the insurer class, how CMS will measure the allowable threshold within each class, the applicability of the rule and hold harmless requirements to non-Medicaid assessments, and how CMS intends to interpret statutory language. Those are all issues stakeholders may want to address in their comments. 

How HMA Can Help 

Although CMS’s proposal focuses on implementing Medicaid financing reforms enacted by Congress, the effect may extend beyond Medicaid to include insurer assessments, Marketplace funding, reinsurance programs, and state affordability initiatives. Until CMS provides clarification, states and insurers will likely continue evaluating potential operational, fiscal, and policy implications. 

HMA Medicaid financing, federal policy, actuarial, and Marketplace experts are helping states, health plans, provider organizations, and other stakeholders evaluate the proposed rule, assess potential impacts, and develop comment strategies.  

HMA and its companies, including Wakely and Leavitt Partners, can support strategic planning, design and implementation of SBMs, Medicaid and Marketplace policy development and regulatory compliance, actuarial analysis, data development and reporting. Connect with us to learn how we can help your organization navigate the federal and state policy changes. Access additional insights from the ACA Marketplace team here.  

CMS Proposed Rule (CMS-2452-P) Could Reshape State Health Insurer Assessments—and Put Marketplace and Reinsurance Funding at Risk

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What CMS-2452-P Means for State-Based Marketplaces, Section 1332 Reinsurance Programs, the individual market, and Medicaid Financing

On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) released the Amending the Indirect Hold Harmless Threshold of Health Care-Related Taxes Proposed Rule (CMS-2452-P) to implement Section 71115 of the 2025 budget reconciliation legislation, P.L. 119-21, now known as the Working Families Tax Cut.

Although the proposal is primarily intended to reform Medicaid financing and provider taxes, it raises broader questions about whether state assessments on commercial health insurers—including those used to fund State-Based Marketplaces (SBMs), Section 1332 reinsurance programs, and other state affordability initiatives—could become subject to new federal limitations.

HMA’s latest analysis examines the proposed rule, explains the policy changes, and explores the potential implications for states, insurers, Marketplace authorities, and policymakers.

Download the full white paper to understand what CMS is proposing, what remains unclear, and what organizations should be monitoring as the rulemaking process continues.

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Executive Summary

CMS Proposed Rule CMS-2452-P would establish a new permissible provider tax class for the “services of health insurers.” Although the proposal is framed as implementing Medicaid financing reforms under Section 71115 of the 2025 budget reconciliation legislation, now known as the Working Families Tax Cut, it introduces uncertainty about whether insurer assessments used to finance commercial market programs—including State-Based Marketplaces and Section 1332 reinsurance programs—could also become subject to Medicaid provider tax requirements.

The proposed rule is unclear as to whether these new limitations apply only to taxes associated with Medicaid financing or extend more broadly to commercial insurance assessments. That distinction could have significant implications for states that rely on insurer assessments to support Marketplace operations, affordability programs, and other insurance initiatives.


Key Takeaways

  • CMS proposes creating a new permissible provider tax class for services of health insurers.
  • The proposal implements Section 71115 of the Working Families Tax Cut Act, which changes the indirect hold harmless thresholds for healthcare-related taxes.
  • The rule is primarily focused on Medicaid financing, but its language raises questions about commercial insurer assessments.
  • State-Based Marketplaces (SBMs) and Section 1332 reinsurance programs may face uncertainty if existing insurer assessments become subject to the new framework.
  • CMS has not clearly explained whether the proposal applies only to Medicaid financing or to all state insurer assessments.
  • States, insurers, and Marketplace leaders are expected to seek additional clarification during the public comment process.

What You’ll Learn from This White Paper

This paper explains:

  • What CMS Proposed Rule CMS-2452-P would change
  • How Section 71115 of the Working Families Tax Cut Act modifies provider tax rules
  • Why states are closely evaluating the proposal
  • Potential implications for State-Based Marketplaces
  • Possible effects on Section 1332 waiver reinsurance programs
  • How the proposal compares with CMS’s 2019 Medicaid Fiscal Accountability Regulation (MFAR)
  • Key policy questions CMS has yet to answer
  • What states, insurers, and Marketplace organizations should monitor moving forward

Frequently Asked Questions

What is CMS-2452-P?

CMS Proposed Rule (CMS-2452-P) would implement Section 71115 of the Working Families Tax Cut Act (WFTCA) by modifying the federal indirect hold harmless framework for healthcare-related taxes and creating a new permissible tax class for services of health insurers.

What does Section 71115 of the WFTCA do?

Section 71115 replaces the historical nationwide indirect hold harmless threshold with new state-specific and provider class-specific limits for healthcare-related taxes used in Medicaid financing.

Could this proposal affect State-Based Marketplaces?

Potentially. Many State-Based Marketplaces are funded through assessments on commercial health insurers. The proposed rule does not clearly explain whether these assessments would become subject to the new provider tax framework.

Could Section 1332 reinsurance programs be affected?

Possibly. Many Section 1332 reinsurance programs rely on insurer assessments to support state funding. If CMS interprets the proposal broadly, future changes to these assessments could face new federal limitations.

Does the proposed rule apply only to Medicaid financing?

This remains one of the most important unanswered questions. The proposal is issued under Medicaid financing authority but introduces a new insurer tax class without clearly defining whether it applies exclusively to Medicaid-related taxes or more broadly to commercial insurance assessments.

Why should insurers and states pay attention?

If finalized as broadly interpreted, the proposal could affect future funding flexibility for State-Based Marketplaces, Section 1332 waiver programs, and other state affordability initiatives financed through insurer assessments.


Why It Matters

State governments increasingly rely on commercial insurer assessments to finance programs that improve health coverage affordability and stabilize insurance markets.

These funding mechanisms support:

  • State-Based Marketplace operations
  • Section 1332 reinsurance programs
  • Individual market affordability initiatives
  • Other state programs

If CMS ultimately determines that these assessments fall within the new health insurer tax class established in Section 71115, states may face new constraints on increasing existing assessments or creating new funding mechanisms after July 4, 2025.

Because the proposed rule does not clearly answer this question, states and insurers face considerable policy uncertainty while CMS completes the rulemaking process.


How This Proposal Differs from the 2019 MFAR Rule

CMS previously proposed creating a health insurer tax class in the 2019 Medicaid Fiscal Accountability Regulation (MFAR).

However, today’s proposal differs in one important way. Since Congress enacted Section 71115 of the Working Families Tax Cut Act, the proposed insurer tax class would now operate within a new statutory framework that includes state-specific indirect hold harmless thresholds. As a result, the potential policy implications extend beyond those in the 2019 proposal.


Why HMA’s Analysis Matters

HMA’s policy experts, actuaries, Medicaid financing specialists, and Marketplace consultants work with states, health plans, and public agencies across the country to evaluate federal policy changes and their operational and financial impacts.

The proposed rule leaves several important policy questions unresolved. Understanding its potential implications now can help states, insurers, Marketplace leaders, and policymakers prepare for future regulatory changes.

Download HMA’s full analysis to explore the proposal in greater detail, understand its potential impacts, and identify key questions that may shape the final rule.


Need Assistance?

HMA’s experts advise states, health plans, Marketplace authorities, and other healthcare stakeholders on Medicaid financing, Section 1332 waivers, Marketplace operations, actuarial strategy, and federal regulatory implementation. If you have questions about how CMS Proposed Rule CMS-2452-P could affect your organization, contact one of the report authors to discuss your specific circumstances.

How CMS’s Proposed MSSP Changes Could Strengthen ACO Growth and Sustainability

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Last week’s Health Management Associates (HMA) Weekly Roundup reviewed the Calendar Year (CY) 2027 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; and Medicare Prescription Drug Inflation Rebate Program (PFS) proposed rule (CMS-1848-P). That overview highlighted provisions that signal a broader shift in how the Centers for Medicare & Medicaid Services (CMS) is approaching physician payment, primary care, digital healthcare, and value-based care. 

This week, our focus turns to the rule’s proposed changes to the Medicare Shared Savings Program (MSSP). 

Why CMS Is Proposing MSSP Changes 

The proposed updates are designed to address feedback and challenges that accountable care organizations (ACOs) have identified over multiple agreement periods, including benchmark volatility, concerns about rebasing, and questions about whether financial incentives adequately reward ongoing performance. 

CMS is seeking to make the program more predictable while continuing to encourage accountability for quality and total cost of care. The proposals also reflect broader agency goals to make the MSSP more attractive to current and prospective ACOs, strengthen primary care, and improve access for beneficiaries in underserved and provider shortage areas. The impact, however, will vary by region and practice. 

In a July 27, 2026, paper, CY 2027 MSSP Proposed Rule Analysis: What the Medicare Shared Savings Program Changes Mean for ACOs, Wakely, an HMA Company, explains that the financial effect of certain provisions depends on an ACO’s track, agreement period, historical savings, regional efficiency, risk profile, beneficiary assignment, and provider growth strategy. 

Key Proposed Changes to MSSP 

Several proposed changes stand out for ACO leaders and provider organizations, including: 

  • Higher Shared Savings for BASIC Level E ACOs. CMS proposes to increase the BASIC Level E shared savings rate from 50 percent to 60 percent for agreement periods beginning in 2027 or later. This change could make the highest-risk BASIC track more attractive relative to other options and improve financial returns for ACOs that are successfully managing cost and quality performance. 
  • Changes to Benchmark Methodology. CMS proposes to modify how prior savings are incorporated into future benchmarks. The changes are intended to better recognize organizations that have generated savings while addressing long-standing concerns among providers that benchmark rebasing can diminish incentives for high-performing ACOs over time. 
  • New Accountable Care Prospective Trend (ACPT) Guardrails. The proposal would establish guardrails and annual recalculation mechanisms for the ACPT to reduce the likelihood that prospective spending projections diverge significantly from actual national cost trends. CMS also proposes applying certain guardrail provisions to payment years 2025 and 2026, potentially before many 2027 provisions take effect. For agreement periods beginning in 2027 or later, CMS proposes a two-sided guardrail and annual recalculation approach designed to reduce the risk that the prospective trend materially diverges from observed national spending trends.
  • Qualifying Provider Network Growth Incentive and Quality Reporting Updates. CMS proposes a new incentive to support ACO growth and participation. Provider entities should evaluate how beneficiary assignment interacts with provider expansion. As Wakely’s actuaries note, adding providers does not necessarily translate into meaningful assignment growth or financial benefit. The proposed rule also includes changes to quality reporting policies intended to reduce administrative burden and better align program operations with care delivery realities, particularly in rural and underserved areas and markets with access constraints. 

Potential Market-Shifting Effects 

The proposed MSSP changes could influence market behavior beyond annual participation decisions. By making changes to BASIC Level E economics, refining benchmark rules, and adding protections against certain trend-related volatility, CMS may encourage more organizations to consider where they want to be on the spectrum of risk -based arrangements.  

Regionally efficient ENHANCED ACOs that rebase or enter the program in 2027 could face less favorable benchmark adjustments. Lower-risk ACOs may have less room under the proposed risk-adjusted benchmark cap. Organizations that pursue provider growth without corresponding increases in assigned beneficiaries may not realize the intended network growth incentive. These dynamics could create winners and losers based on local market position, historical performance, patient mix, and each organization’s financial and operational strategy. 

How HMA and Wakely Can Help 

ACO and provider leaders should use the proposed rule period to assess how the MSSP changes could affect their 2027 strategy and near-term financial projections. Current ACOs should revisit payment year 2025 and 2026 forecasts, evaluate the proposed ACPT guardrail, and model how the 2027 benchmark changes may affect renewal, track selection, and downside risk exposure. Organizations considering MSSP entry should evaluate whether the proposed changes improve the business case for participation and what capabilities would be needed to succeed. 

Although the proposals focus on MSSP, their significance extends beyond Medicare ACOs. The changes reflect CMS’s broader effort to strengthen participation incentives, improve benchmark stability, and refine value-based payment models based on operational experience. As a result, the proposals may influence how Medicare Advantage plans, Medicaid programs, and commercial payers structure risk arrangements.

Providers and partners should also prepare comments grounded in data and operational experience. HMA and Wakely help ACOs, providers, health systems, payers, enablement organizations, and investors evaluate the policy, actuarial, operational, and market implications of Medicare accountable care changes. Our teams support MSSP strategy, benchmark and shared savings modeling, risk assessment, provider network analysis, care management design, comment letter development, and implementation planning. 

As CMS considers comments and moves toward a final rule, organizations should not wait to understand how the proposed MSSP changes could affect participation decisions, market strategy, and accountable care capabilities. HMA and Wakely can help stakeholders translate the proposed rule into actionable scenarios and prepare for the financial and operational choices ahead. 

Outlook 2026: New Guidance Raises the Bar for Medicaid 1115 Demonstration

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As part of its ongoing effort to reshape Medicaid policy and oversight, the Centers for Medicare & Medicaid Services (CMS) over the past few months has released a series of guidance documents in 2026 that collectively signal a more structured, fiscally rigorous approach to federal Medicaid funding. These changes will have a considerable impact on state innovation within the program.

In the most recent of these consequential directives, CMS outlines its plan to implement updated budget neutrality requirements for Medicaid Section 1115 demonstrations beginning in 2027.

To understand what this guidance means for states, health plans, and providers, Health Management Associates (HMA) senior principal Andrea Maresca caught up with Sara Singleton, Principal at Leavitt Partners, an HMA Company, and Rob Buchanan, Senior Principal at HMA. Of particular interest was the need for significantly more robust modeling and financing strategies to provide the new prospective actuarial analyses required for approval.

A Shift in Federal Policy Direction

Q: CMS has issued several guidance documents this year, but why and how does the one on Section 1115 budget neutrality stand out?

Sara Singleton: This guidance reflects a broader shift toward increased federal oversight and a more standardized interpretation of budget neutrality. While Section 1115 demonstrations have always been required to be budget neutral in concept, CMS and states have historically relied on methodologies that allowed for flexibility and, in some cases, greater federal spending over time.

What’s different now is that Congress recently added a requirement that the CMS Chief Actuary certify that demonstrations will not increase federal expenditures relative to what Medicaid would otherwise spend. That requirement, combined with CMS’s implementing guidance, is driving a more prospective, and in theory, data-driven approach to evaluating demonstrations.

Q: How is the change from reviewing retrospective to prospective spending expected to affect Medicaid programs?

Sara Singleton: Historically, CMS often reviewed budget neutrality retrospectively against what’s called “without waiver” spending limits, which means the agency reviewed what spending would have been in the absence of the waiver program. Going forward, CMS is emphasizing prospective certification and signals an expectation that states will provide more rigorous actuarial analysis and activity-level financial modeling.

The implication is that states will need to demonstrate upfront and in much greater detail how each component of their demonstrations affect federal spending. This is a substantive change in expectations for documentation, analytics, and accountability.

Implications for Innovation, Including HRSN Initiatives

Q: Sara, you’ve written previously about the opportunities to address health-related social needs (HRSN) through Medicaid. How does this new guidance intersect with those efforts?

Sara Singleton: The timing is important. Over the past several years, the number of states utilizing 1115 waivers to address HRSNs, such as housing instability, nutrition, and transportation, has significantly increased. Many of these waivers and additional research have proven what we have long known to be true—that addressing HRSNs has a clear impact on health outcomes and costs.

The new budget neutrality framework raises the bar for states to demonstrate that new innovations in an 1115 waiver will reduce costs before the waiver can be approved. States will need to show not just that these services are beneficial, but that they also are financially sustainable within the federal budget neutrality test. That’s a higher evidentiary standard, particularly for newer or more complex interventions.

Q: Does that mean HRSN initiatives are at risk?

Sara Singleton: Not necessarily; however, it does mean states may need to rethink how they structure and justify them.

One key element in the guidance is the distinction between services that are already Medicaid-authorizable and those that are unique to Section 1115 demonstrations. CMS is signaling a preference for using existing authorities where possible. CMS’s preference and negotiations with states could lead states to shift some HRSN activities into managed care programs, including using in lieu of services, or state plan options.

For services that remain in 1115 demonstrations, the burden will be on states to build a more robust financial and policy case. That expectation could shape which interventions move forward.

Q: Rob, what are you hearing from states as they process this guidance?

Rob Buchanan: States recognize that Section 1115 demonstrations are critical tools—they allow flexibility to test new delivery models and address complex population needs. In fact, every state has an 1115 demonstration, each with tailored initiatives that span coverage, benefits and services, workforce investments, and other programs. The pathway to approval and iteration of these programs is becoming more complex.

From a planning perspective, states will need to rethink how they approach the entire life cycle of a demonstration—from concept development to modeling, implementation, and evaluation.

Q: Where are the biggest pressure points?

Rob Buchanan: HMA consultants have identified three key areas.

First is analytics and actuarial capacity. The guidance calls for more rigorous financial projections and certification prior to approval, which means states need stronger data infrastructure and modeling capabilities earlier in the process.

Second is program design and prioritization. Because demonstrations that increase federal spending will not be approved, states may need to narrow their focus, phase in initiatives, or identify offsetting savings within the demonstration.

Third is timing and alignment. CMS has indicated it will begin applying this framework in 2027, even as rulemaking continues. States with renewals or amendments coming up in that window will need to move quickly to align with the new expectations.

Q: How should states begin adapting their strategies?

Rob Buchanan: We’re advising states to start with a few practical steps.

One is to reassess their current demonstration portfolios. Which components are most essential? Which are most likely to meet the new budget neutrality standard? That prioritization will be critical.

Another is to integrate policy, finance, and operations early. Under this framework, you can’t develop policy concepts in isolation. You need to understand the financial implications from the outset.

Finally, states should think about implementation pathways. For example, if certain services can be authorized through managed care or state plan options, that may provide more flexibility than relying solely on Section 1115 authority.

Q: Does this change how states should think about partnerships?

Rob Buchanan: Yes, the level of coordination required across Medicaid agencies, actuaries, managed care plans, providers, and community organizations is increasing.

States will need strong partnerships to both design workable demonstrations and execute them effectively. That includes building connections with community-based organizations, particularly for initiatives that address HRSNs, where implementation relies heavily on local networks.

Q: As we look toward 2027 implementation, what should states and other Medicaid-focused organizations be focused on now?

Rob Buchanan: The most important thing is to recognize that this is not a distant policy change. It’s an immediate planning issue and states should already be assessing how the new framework applies to their program.

Compliance with this guidance requires state Medicaid programs to have detailed data  – specifically actuarial analyses that have a clear methodology and assumptions and documentation demonstrating the federal fiscal impact of each demonstration component. States must provide sufficient information for CMS’s Chief Actuary to evaluate and certify budget neutrality. Plans and providers should also be engaged because these changes will influence program design, reimbursement approaches, and operational expectations.

Sara Singleton: At a broader level, stakeholders should expect additional guidance from CMS. This is one piece of a larger policy agenda, and CMS plans to provide additional clarification through the federal rulemaking process as well as technical assistance to states.

HMA, including HMA companies Wakely and Leavitt Partners, is actively helping states, health plans, providers, and other stakeholders assess the implications of CMS’s proposed budget neutrality framework and prepare for upcoming section 1115 renewals and amendments, as well as other changes due to recent guidance on community engagement requirements, state directed payments, and program integrity. HMA can support strategic assessments, renewal planning, demonstration redesign, financial modeling, actuarial coordination, federal negotiations, and implementation planning. Connect with HMA to learn how we can support your organization in navigating the next phase of Medicaid Section 1115 demonstration and policy.

You can find more insights on the impact of federal Medicaid policy changes in, CMS Proposes New Budget Neutrality Framework for Medicaid Section 1115 Demonstrations and register for the next edition of HMA’s Summer Webinar Series: Understanding Work and Community Engagement Requirements and New Section 1115 Guidance

New Funding Approaches Prompt Maryland Healthcare Leaders to Reassess Strategies for Affordable Coverage

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Strategies to improve healthcare delivery, sustain coverage, and manage growing cost pressures resulting from federal policy changes and state budget dynamics were key topics of discussion at this year’s Maryland health policy conference, May 21, 2026, in Baltimore, MD. Hosted by State of Reform (SOR), an HMA Company, the program convened state policymakers and leaders of health plans, provider groups, and community-based organizations to examine the most pressing healthcare issues in Maryland.

Across sessions, participants explored key policy priorities, including Maryland’s implementation of the Rural Health Transformation Program (RHTP), efforts to stabilize and expand health insurance coverage, and early lessons from implementing the AHEAD (Achieving Healthcare Efficiency through Accountable Design) total cost of care (TCOC) model. 

Sustaining Medicaid and Marketplace Accessibility Amid Federal Policy Changes 

Throughout the conference speakers and attendees engaged on myriad issues and concerns resulting from the 2025 budget reconciliation act, now referred to as the Working Families Tax Cuts (WFTC) Act, and its potential impact on state Medicaid programs and coverage stability. Maryland Deputy Secretary for Healthcare Financing and Medicaid Director Perrie Briskin joined Johanna Fabian-Marks, Deputy Executive Director of the Maryland Health Benefit Exchange (MHBE), and Melissa Horn, Director of State Legislative Affairs at the Arthritis Foundation, to examine strategies for mitigating coverage loss and maintaining affordability. 

Speakers emphasized the need for improved coordination between Medicaid and the MHBE, including clear and consistent consumer communications and targeted outreach in counties most affected by federal policy changes. 

For example, Maryland leaders described several innovative approaches the MHBE is using to help people in the state maintain Marketplace coverage, including state-funded subsidies to offset the expiration of enhanced premium tax credits, streamlined auto-renewals, and simplified enrollment pathways for individuals identified as uninsured based on their tax and employment records. The state reported an 8 percent decline in enrollment in April 2026, noting that without these mitigation strategies, enrollment could have dropped by as much as one-third. 

The MHBE is using artificial intelligence (AI) to support document verification and is deploying a chatbot to help consumers navigate common questions. 

On the Medicaid side, the state is consulting multiple data sources—including CRISP (Chesapeake Regional Information System for our Patients), labor, and education data—to verify eligibility and, compliance with community engagement requirements to reduce administrative burdens.

Rural Health Transformation Program Implementation and Early Priorities 

Maryland’s RHTP, supported by nearly $168.2 million in first-year funding from the Centers for Medicare & Medicaid Services (CMS), was a hot topic at the conference. State leaders and implementation partners emphasized the program’s role in addressing rural health disparities, strengthening care delivery infrastructure, and improving chronic disease outcomes.

Elizabeth Kromm, PhD, Assistant Secretary, Maryland Department of Health, outlined the three pillars of the state’s RHTP plan: 

  • Expand the rural healthcare workforce 
  • Increase access to integrated primary, specialty, and behavioral health services 
  • Address the underlying drivers of chronic disease through nutrition and food system interventions 

Together, these initiatives highlight Maryland’s focus on both clinical care delivery and broader population health strategies. 

State officials also discussed the funding opportunities announced in April 2026, one of which seeks to support care delivery innovation, improve chronic condition management, and advance value-based care models. Speakers emphasized that connection is central to the program’s success—both the strength of community relationships, the connections enabled through technology, and the integration of clinical and nonclinical services. 

AHEAD Model: Advancing Total Cost of Care and Population Health 

Maryland’s participation in CMS’s AHEAD Model represents a significant shift toward healthcare cost containment and system transformation. As one of the first states to implement the framework, Maryland is testing a statewide approach to managing TCOC while improving quality and population health outcomes. 

A panel discussion including leaders from the MedChi, Johns Hopkins, CareFirst Blue Shield, and Kaiser Permanente, addressed implementation considerations, open policy implications, and how providers and payers were approaching these changes in payment for healthcare services. Reimbursement strategies for primary care services were still uncertain and may differ significantly from those used under the Maryland TCOC model. Panelists also discussed what this model means in the broader healthcare environment of reductions in Medicaid payments resulting from the reconciliation legislation and additional funding coming from the Rural Health Transformation Fund. They also described how Maryland could serve as an example for other states working to implement AHEAD in the coming years. 

Speakers noted that successful implementation will require strong coordination among providers, payers, and state agencies, and more details are necessary to fulfill the requirements. The model’s 10-year timeline positions Maryland as a leading test case for future federal and state efforts to scale TCOC approaches. 

AI in Healthcare: From Innovation to Real-World Impact 

AI’s role in healthcare delivery and policy continues to evolve, with growing attention on its practical applications and regulatory implications. A session led by Health Management Associates (HMA) Principal Brandon Greife, JD, and speakers from Microsoft AI, the Pair Team, the Center for Virtual Care, and b.well Connected Health explored how healthcare organizations conceptualize AI use cases to deploy solutions that demonstrate measurable impact. 

AI holds promise for improving care delivery, but realizing that potential requires navigating ethical, regulatory, and operational challenges. Mr. Greife led a panel discussion on how the healthcare industry is transitioning from abstract use cases for AI toward evaluating the real-world impact of deployed solutions. 

Session speakers also explored how healthcare is advancing from AI tools that support clinicians and payers to patient-facing AI that supports care navigation, chronic disease management, and community outreach. They rounded out the session with a focus on fundamentals of healthcare—concepts like data quality, clinical trust, patient safety, and demonstrated value at the point of care. 

Looking Ahead 

If you are looking for strategies and solutions to address urgent healthcare policy and operational challenges, HMA experts are available to help you navigate these complex changes and identify practical paths forward. 

Through the HMA National ConferenceState of Reform partnership events, and other HMA convenings across the country, we connect state leaders, providers, health plans, and community stakeholders to share insights, elevate lessons, and advance solutions. Join us at an upcoming event—including our next HMA National Conference in New Orleans, LA on October 5-7, 2026—or explore additional opportunities to engage with HMA and access the full schedule of conferences and resources. 

State of Reform develops its conference agendas through collaboration with HMA subject matter experts/market leads and stakeholders across the public and private sectors, including state officials, community-based organizations, providers, payers, and more. 

Medicaid Community Engagement Interim Final Rule: Key Implications for States, Payers, and Providers

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HMA’s issue brief on the Medicaid Community Engagement Interim Final Rule provides a clear, actionable summary of new Medicaid work requirements and community engagement requirements for states, Medicaid health plans, providers, community-based organizations, and technology vendors. The report explains key policy changes issued by CMS on June 1, 2026, including exemptions such as medical frailty, verification and reporting expectations, enrollee notification requirements, and the state systems changes needed to prepare for the January 1, 2027 implementation deadline. If you are searching for a summary of Medicaid work requirements, a summary of Medicaid community engagement requirements, the medical frailty definition, or guidance on Medicaid work requirements state systems changes, this brief helps translate complex federal regulation into practical next steps to support compliance, reduce coverage loss risk, and inform implementation strategy.

Please fill out this form to receive a copy of the issue brief.

Join us at HMA’s 2026 National Conference: Signals, Signs & Flashing Lights

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Registration is now open for the Health Management Associates (HMA) 2026 National Conference, US Healthcare 2026: Signals, Signs & Flashing Lights, October 5–7 in New Orleans, LA. 

HMA’s conference is intentionally structured to bring together leaders who are shaping decisions across sectors—those setting policy, managing risk, leading clinical operations, and innovating approaches to improve outcomes—to engage in candid conversations about what is working, what is not, and what is changing in Medicare, Medicaid, Marketplace and adjacent programs. In an environment defined by new challenges and “flashing lights,” even the most seasoned healthcare leaders will find value in stepping out of their day‑to‑day roles to compare strategies, test assumptions, and learn from peers facing similar pressures. 

This year’s conference is designed to reflect the environment healthcare leaders are navigating today—one defined less by policy certainty and more by shifting expectations and competing pressures on cost, access, and performance. Our experts are crafting discussions to address how organizations are approaching policy engagement in this environment, including new strategies for interpreting signals from federal and state policymakers and negotiating policy frameworks that directly shape market dynamics. 

Across plenary sessions, breakout discussions, and HMA’s signature coffee conversations, the conference will focus on how organizations are interpreting these signals and translating them into practical strategies. 

Programming will center on four cross-cutting themes shaping healthcare decision-making: 

  • Managing risk and cost amid continued financial pressure. Discussions will examine the drivers of utilization and affordability trends across Medicare, Medicaid, and commercial markets and which strategies are demonstrating measurable impact. 
  • Sustaining access and system stability. The agenda also will focus on how providers, health systems, and state programs are maintaining access amid workforce challenges, coverage transitions, and ongoing financial strain.
  • Turning innovation into impact. Sessions will explore where artificial intelligence (AI) and digital health tools are delivering measurable operational or clinical impact and what it takes to implement them effectively. 
  • Building partnerships that last. Conversation will highlight how stakeholders are aligning incentives, funding, and strategy to move from short-term responses to long-term, sustainable solutions. 

As in prior years, the HMA National Conference is structured to support candid dialogue, actionable takeaways, and meaningful connections. Attendees consistently highlight the opportunity to move beyond high-level trends and engage in practical discussions that inform decision-making in their organizations. 

Early-bird registration is now available for a limited time. The 2026 Sponsor Prospectus includes new opportunities for your organization. Additional agenda details, featured speakers, and interactive programming announcements will be released in the coming weeks. 

Webinar Replay – ACA Enrollment Declines: Implications and Options for State and Federal Policymakers

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This webinar was held May 21, 2026.

Recent and future policy changes are reshaping the ACA market. A recent Wakely report finds that only 86% of ACA enrollees nationwide paid their first premium at the start of the year, raising important questions about affordability, access, and market stability. Additionally, the 2027 Notice of Benefits and Payment Parameters (NBPP) is expected to be finalized this Spring which will have additional implications for consumers, issuers, and other stakeholders. As policymakers and state leaders consider how to respond to the shifting market composition and future policy changes, this discussion will focus on the policy implications of these shifts and the options to address affordability and coverage options to improve market stability.

During this webinar, HMA’s ACA team had a policy-focused conversation on what these projected changes mean for marketplace dynamics, including impacts to risk pools, premiums, and issuer participation. The session explored emerging federal and state policy responses and offered insight into how today’s decisions may shape 2027 rates, plan offerings, and long-term market sustainability.

Learning Objectives:

  • Analyze policy drivers: Examine how changes to federal subsidy policy are influencing ACA marketplace enrollment, affordability, and coverage continuity.
  • Evaluate policy tradeoffs: Assess how enrollment declines impact market stability, including risk pools, premiums, and issuer participation.
  • Inform policy strategy: Identify state and federal policy options to mitigate coverage losses and support a stable, competitive marketplace heading into 2027.
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