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Medicaid Funding Changes, Eligibility Requirements, and the Safety Net: What Community Leaders Need to Know

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HMA Solutions

Medicaid Funding Changes, Eligibility Requirements, and the Safety Net: What Community Leaders Need to Know

Federal policy and funding changes are reshaping Medicaid, healthcare delivery, human services, and the local safety net. HMA helps healthcare, Medicaid, human services, and community leaders assess the impact of federal funding changes, protect access to care, strengthen local safety-net systems, and develop practical implementation strategies.

Communities Face Converging Fiscal and Service Pressures

Changes to Medicaid financing, eligibility, and community engagement requirements will not remain contained within state Medicaid agencies. The effects can move across health systems, local government, human services programs, community-based organizations, and households. When coverage becomes harder to maintain, people still need care and support. The costs and responsibilities often surface elsewhere in the community.

Hospitals and healthcare providers may face greater uncompensated care and pressure on already vulnerable service lines. Counties and municipalities may encounter increased demand for behavioral health, public health, housing, emergency response, and other locally supported services. Human services agencies may need to implement more complex processes without additional workforce capacity. Community-based organizations may be asked to help people navigate new requirements while also managing reductions or instability in their own funding.

These pressures will not be distributed evenly. Children and families, people with disabilities, older adults, rural residents, people experiencing homelessness, low-income working adults, pregnant and postpartum people, individuals with behavioral health needs, and people involved with child welfare systems may face heightened risk when administrative complexity and service constraints increase.

Supporting the Leaders Closest to Community Impact

HMA works with the organizations responsible for financing, administering, delivering, and sustaining healthcare and community supports.

State Medicaid agencies, health and human services departments, and executive and legislative leaders

Counties, municipalities, public health agencies, and local human services systems

Hospitals, rural health organizations, safety-net providers, health plans, and provider associations

Behavioral health organizations, child welfare agencies, housing and homelessness systems, and family-serving organizations

Community-based organizations, coalitions, foundations, associations, and cross-sector partnerships

Our multidisciplinary teams connect Medicaid and healthcare expertise with human services, community systems, organizational strategy, operations, financing, analytics, and implementation support. That breadth allows HMA to help clients understand not only what a policy change requires, but also how the change will affect people, providers, partners, workflows, budgets, and outcomes.

HMA Can Help Leaders Move from Uncertainty to Action

HMA can tailor support to a single organization, local community, statewide system, or cross-sector coalition. Engagements may include rapid analysis, operational planning, stakeholder engagement, implementation support, and performance monitoring.

Assess Policy and Fiscal Impact

Translate federal and state changes into clear implications for coverage, enrollment, provider reimbursement, service utilization, administrative cost, workforce demand, and local government exposure.

How HMA helps: Policy analysis, fiscal-impact assessment, coverage and enrollment scenario planning, provider vulnerability analysis, local cost-shift analysis, and executive briefings.

Prepare Medicaid and Eligibility Operations

Help agencies and partners prepare for eligibility, verification, reporting, data-matching, communication, and coverage-retention challenges while reducing avoidable administrative burden.

How HMA helps: Operational readiness assessments, workflow mapping, data-gap analysis, implementation roadmaps, community communications, and performance measures.

Evaluate Safety-Net and Provider Vulnerability

Identify where reductions in coverage or reimbursement may threaten access, critical service lines, rural providers, behavioral health capacity, maternity care, specialty services, and community-based care.

How HMA helps: Provider and service-line vulnerability assessments, market and network analysis, rural access review, scenario modeling, mitigation planning, and monitoring dashboards.

Strengthen Community Infrastructure

Assess whether community-based organizations and local partners have the capacity, funding, data, referral relationships, and operating infrastructure needed to absorb new responsibilities.

How HMA helps: CBO capacity and sustainability assessments, referral-network mapping, partnership strategy, reimbursement opportunity analysis, sustainability planning, and technical assistance.

Build Cross-Sector Response Plans

Bring healthcare, Medicaid, human services, public health, housing, workforce, philanthropy, and community partners together around shared risks, priorities, roles, resources, and accountability.

How HMA helps: Stakeholder engagement, facilitated convenings, governance design, shared implementation planning, resource mapping, and accountability frameworks.

Redesign Human Services and Community Systems

Help agencies align policy, funding, operations, workforce, technology, community voice, and performance expectations so systems can function more effectively under constraint.

How HMA helps: Current-state assessments, operating-model redesign, workforce strategy, change management, implementation tools, and continuous quality improvement structures.

Develop Sustainable Financing Strategies

Help clients move beyond reliance on a single funding source by identifying opportunities to maximize, blend, braid, and sequence public and private resources.

How HMA helps: Funding opportunity scans, Medicaid optimization, financing and reimbursement strategy, financial modeling, grant and partnership strategy, and sustainability roadmaps.

Use Data to Target Resources and Track Results

Combine policy, fiscal, enrollment, utilization, geographic, provider, and community information to identify hotspots, prioritize resources, and monitor whether implementation is protecting access.

How HMA helps: Data inventory and gap assessments, community indicator mapping, geographic hotspot analysis, dashboards, performance measures, and evaluation plans.

Questions Leaders Should Be Asking Now

HMA Has the Right Team

HMA brings deep Medicaid, healthcare, human services, financing, implementation, and community-system expertise to help clients translate policy change into operational readiness, protect access to care, strengthen safety-net infrastructure, and coordinate action across providers, agencies, local governments, and community partners.

Connect with HMA to discuss what the changing fiscal landscape means for your state, community, organization, providers, and residents.

Why Is Medicaid Program Integrity More Than Fighting Fraud?

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In this episode of Vital Viewpoints on Healthcare, Clint Eisenhower, regional director at Health Management Associates, discusses the critical role of Medicaid program integrity and why it is about much more than preventing fraud. Drawing on his experience leading state and federal Medicaid program integrity organizations, Clint explains how protecting taxpayer dollars, managing enterprise risk, and ensuring the right people and processes are in place all contribute to stronger healthcare programs. He also explores common misconceptions about program integrity and shares why this work is essential to maintaining trust, accountability, and the long-term sustainability of Medicaid.

2027 Maternity Care Coding Changes: How Providers, Health Plans, and States Can Prepare for Service-Level Reimbursement

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What the shift away from global obstetric billing may mean for care delivery, coding and documentation, reimbursement, quality measurement, and more.

AT A GLANCE: Beginning January 1, 2027, maternity care reimbursement will change from bundled global obstetric codes toward more granular, service-level reporting for antepartum care, labor management, delivery, and postpartum care. The new approach is intended to more accurately capture how maternity care is delivered today across multiple clinicians, settings, modalities, and risk profiles. Organizations should begin assessing operational, financial, contracting, and data implications now.

What Is Changing?

Under the new approach, maternity services will be recognized and reported at the service level rather than through a single global obstetric payment. The impacts will unfold over time and will depend on final policy, coding guidance, fee schedules, contracts, and implementation decisions specific to payers, providers, and local markets.

What This Will Mean?

This change is more than a coding update. It will affect payment policy, claims systems, documentation workflows, actuarial assumptions, provider contracts, quality and access monitoring, data reporting, and patient care models. For Medicaid agencies, health plans, federally qualified health centers (FQHCs), hospitals, physician and midwifery practices, and professional associations, the transition creates implementation risks and uncertainties as well as opportunities to modernize maternitycare financing around person-centered perinatal care, social needs screening and management, telemedicine, home monitoring, and postpartum support. Early preparation can reduce disruption and enable increased visibility into access, quality, equity, outcomes, and total cost.

New Questions Stakeholders Will Need to Answer

  • How will payment rates, fee schedules, and contracts change when maternity care is no longer paid as a single global payment?
  • What documentation, coding, and billing workflows will providers need to update before the new codes (and/or potential interim codes, depending on the Centers for Medicare & Medicaid Services (CMS) decision-making) take effect in order to ensure that care is correctly reimbursed?
  • What systems changes and staff training will be needed?
  • What claims edits, utilization management rules, encounter data processes, and reporting systems will need to be revised?
  • How will payers distinguish routine care, higher-risk care, care coordination, social needs services, telehealth, and home monitoring?
  • How can stakeholders use new data to assess access, quality, equity, outcomes, and total cost of maternity care?

Supporting Next Steps

HMA can help stakeholders understand the implications of the new coding structure, evaluate policy and operational options, create a practical path forward, and operationalize that plan across programs, systems, contracts, and care delivery models.

StakeholderHow HMA Can HelpHMA Services Include
StatesAssess Medicaid policy impacts, update provider guidance, model budget and rate implications, align managed care contracts, and design monitoring strategies for access, quality, equity, and outcomesRevenue Cycle Management

Actuarial Analysis

Market Analysis and Strategic Planning

Financial Modeling

Operational Planning and Implementation Support

Research and Evaluation

Contract Review and Negotiation Support

Business Analytics

Clinical and Health-Related Social Needs Service Model Development

Quality Measurement and Accreditation Support

Information Technology Advisory Services    
Providers: FQHCs, hospitals, physician practices, and midwifery groupsHelp organizations prepare for coding, documentation, billing, revenue cycle, and clinical workflow changes; identify training needs; and evaluate how new payment rules affect service delivery and financial sustainability
Health plansRevise payment policies, claims logic, provider communications, contract terms, encounter data processes, and network oversight approaches to support a smooth transition
Associations and coalitionsTranslate the changes for members, develop implementation roadmaps, convene stakeholders, identify advocacy priorities, and support coordinated action across the maternity care environment

Frequently Asked Questions

What is changing in maternity care reimbursement in 2027?

Maternity care reimbursement is shifting from bundled global obstetric billing toward more granular, service-level reporting for antepartum care, labor management, delivery, and postpartum care.

Who will be affected by the maternity care coding changes?

OB/GYN practices, hospitals, FQHCs, midwifery groups, health plans, Medicaid agencies, professional associations, and other organizations involved in maternity care financing, delivery, claims, contracting, or oversight will be affected by these significant changes.

What should organizations do first?

Start with an impact assessment: inventory current payment arrangements, map services and documentation, identify systems changes and training needs, model financial effects, review contracts, and develop implementation roadmaps.

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. 

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. 

For more information, go to: https://www.healthmanagement.com/services/our-medicaid-consultants-help-you-develop-innovative-strategies/

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 States Are Implementing Medicaid Section 1115 Justice-Involved Reentry Demonstrations

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Medicaid Section 1115 Justice-Involved Reentry Demonstrations allow states to provide selected Medicaid-covered services before an individual is released from incarceration. This report highlights the operational, governance, technology, and care coordination strategies needed for successful implementation across multiple jurisdictions.

HMA’s new report, Lessons Learned from Implementing 1115 Justice-Involved Reentry Initiatives: Strategic Planning and Operational Considerations, shares practical implementation strategies, lessons learned, and operational best practices drawn from supporting justice-involved healthcare initiatives in multiple states. For organizations strengthening an existing program or preparing for a new demonstration, the report offers actionable guidance to improve implementation readiness, reduce operational risk, and build sustainable systems that support better outcomes for justice-involved populations.

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Key Takeaways

Readers will learn how successful organizations are:

  • Building governance structures that align corrections, Medicaid, healthcare providers, and community partners
  • Designing operational workflows that support seamless transitions from incarceration to community care
  • Preparing correctional facilities, managed care organizations, and providers for new responsibilities
  • Addressing technology, interoperability, eligibility, and data-sharing challenges
  • Creating person-centered care coordination models that improve continuity of care
  • Identifying implementation risks before they become operational barriers
  • Using performance measurement and continuous quality improvement to strengthen long-term program success

Why Medicaid Section 1115 Justice-Involved Reentry Demonstrations Matter

For decades, individuals leaving incarceration have faced significant barriers to accessing healthcare. Interruptions in Medicaid coverage, gaps in medication, delayed connections to primary care and behavioral health services, fragmented care coordination, and limited communication between correctional and community providers have contributed to poorer health outcomes and increased reliance on emergency and crisis services.

Medicaid Section 1115 Justice-Involved Reentry Demonstrations are designed to address these long-standing challenges by allowing eligible individuals to receive selected Medicaid-covered services before being released from incarceration. Early engagement with healthcare providers establishes care prior to reentry, improves coordination with community-based organizations, and strengthens transitions into ongoing medical, behavioral health, and social support services.

As more states implement Medicaid reentry demonstrations, organizations are discovering that operational success depends on thoughtful planning, strong governance, effective partnerships, and sustainable implementation strategies.

Why Organizations Struggle with Implementation

Across states implementing Medicaid Justice-Involved Reentry Demonstrations, several consistent challenges have emerged.

Cross-Agency Governance

Correctional agencies, Medicaid programs, managed care organizations, healthcare providers, behavioral health organizations, and community-based organizations often have different operational processes, funding structures, and priorities. Building shared governance and clear decision-making processes is essential for successful implementation.

Operational Workflow Design

Organizations must create new workflows for eligibility determination, care management, medication continuity, discharge planning, provider referrals, and community handoffs—many of which have never existed before.

Technology and Interoperability

Connecting correctional electronic health records with community healthcare systems remains one of the largest implementation challenges. Secure data exchange, interoperability, privacy requirements, and real-time communication require significant planning and investment.

Workforce Readiness

Successful implementation requires training correctional healthcare staff, case managers, community providers, managed care organizations, and Medicaid partners on new roles, responsibilities, and operational processes.

Care Coordination

Person-centered care coordination begins before release and continues after individuals return to the community. Organizations must establish sustainable partnerships that support continuity of care across healthcare, behavioral health, housing, and social service systems.

The most successful organizations recognize that Medicaid Section 1115 Justice-Involved Reentry implementation is not simply a compliance exercise—it is a comprehensive system transformation effort.

HMA’s Five Pillars of Successful Medicaid Reentry Implementation

Drawing on implementation experience across multiple states, HMA has identified five foundational elements that consistently support successful implementation:

1. Governance and Cross-Sector Collaboration

Building shared leadership, accountability, and decision-making across agencies.

2. Operational Planning

Developing standardized workflows that support eligibility, care coordination, referrals, and continuity of care.

3. Technology and Data Exchange

Improving interoperability between correctional and community healthcare systems while supporting secure information sharing.

4. Person-Centered Care Coordination

Designing services around the needs of individuals transitioning from incarceration into their communities.

5. Continuous Quality Improvement

Using performance measures, implementation feedback, and operational data to improve program effectiveness over time.

Readers will gain insights into:

  • Building effective cross-sector governance and decision-making structures
  • Designing operational workflows that support continuity of care
  • Preparing correctional facilities and community providers for new responsibilities
  • Strengthening partnerships with managed care organizations and Medicaid agencies
  • Addressing technology, interoperability, and data-sharing challenges
  • Developing person-centered care coordination models
  • Measuring performance and using continuous quality improvement to refine implementation
  • Identifying common risks before they become operational barriers

Rather than focusing solely on policy requirements, the paper emphasizes the organizational strategies that position programs for long-term success.

Who Should Read This Report?

This report is designed for leaders responsible for planning, implementing, financing, managing, or overseeing Medicaid Section 1115 Justice-Involved Reentry Demonstrations, including:

  • State Medicaid agencies
  • Departments of Corrections
  • County jail administrators
  • Probation and parole agencies
  • Managed care organizations
  • Correctional healthcare providers
  • Behavioral health providers
  • Federally Qualified Health Centers (FQHCs)
  • Community-based organizations
  • County and state policymakers
  • Healthcare executives
  • Medicaid program managers
  • Reentry program leaders
  • Population health and care management leaders

Whether your organization is launching a new demonstration or refining an existing implementation strategy, this report provides actionable guidance that can accelerate implementation while improving long-term outcomes.

Why HMA?

HMA has supported Medicaid agencies, correctional systems, managed care organizations, behavioral health providers, healthcare organizations, and community-based partners across numerous justice-involved healthcare initiatives. Our experience spans policy development, implementation planning, operational design, governance, technology strategy, care coordination, and program evaluation.

The recommendations in this report reflect real-world implementation experience and practical lessons learned from helping organizations navigate the complex operational challenges of Medicaid Section 1115 Justice-Involved Reentry Demonstrations.

Frequently Asked Questions

  • What is a Medicaid Section 1115 Justice-Involved Reentry Demonstration?

A Medicaid Section 1115 Justice-Involved Reentry Demonstration allows eligible individuals to receive selected Medicaid-covered healthcare services before they are released from incarceration. The goal is to improve continuity of care, strengthen transitions to community providers, and improve long-term health outcomes.

  • What are the biggest implementation challenges?

Organizations commonly face challenges related to governance, cross-agency coordination, operational workflow design, technology integration, data sharing, workforce readiness, eligibility processes, and care coordination.

  • Who is responsible for implementing Medicaid reentry demonstrations?

Implementation requires collaboration among state Medicaid agencies, correctional systems, managed care organizations, healthcare providers, behavioral health organizations, community-based organizations, and technology partners.

  • Why is operational planning important?

Successful implementation depends on designing sustainable workflows, governance structures, technology infrastructure, and partnerships that support individuals before release and throughout their transition back into the community.

  • How can organizations improve implementation readiness?

Organizations can improve readiness by establishing cross-sector governance, investing in technology and interoperability, standardizing operational processes, strengthening care coordination, measuring performance, and continuously refining implementation based on lessons learned.

Download the Report

As additional states pursue Medicaid Section 1115 Justice-Involved Reentry Demonstrations, organizations have an unprecedented opportunity to transform how healthcare is delivered to justice-involved populations.

Lessons Learned from Implementing 1115 Justice-Involved Reentry Initiatives: Strategic Planning and Operational Considerations provides practical implementation strategies, operational recommendations, governance models, technology considerations, and lessons learned to help organizations avoid common pitfalls, accelerate implementation, and build sustainable Medicaid reentry programs that improve outcomes for individuals and communities.

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