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Blog

States Begin to Engage with the Rural Health Transformation Program

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The Rural Health Transformation Program (RHTP) established in H.R. 1 represents one of the most significant federal investments in rural healthcare in decades. With $50 billion allocated between fiscal years 2026 and 2030, the program is designed to stabilize and transform rural health systems nationwide by supporting infrastructure, workforce development, and innovative care delivery models.

Administered by the Centers for Medicare & Medicaid Services (CMS), the RHTP requires each state to submit a one-time application detailing a comprehensive rural health transformation plan. These plans must address eight core priorities, including improving access and outcomes, leveraging technology, fostering regional partnerships, and ensuring long-term financial solvency for rural entities. The Centers for Medicare & Medicaid Services (CMS) has posted the federal program page, with application materials expected to become available in mid-September and state submissions due in late fall 2025.

The experts at Health Management Associates, including our Information Services team (HMAIS), are tracking several state-level indicators and actions, including lead state agency points of contact, regulatory and public comment deadlines, and links to official notices. Following are the key takeaways from HMAIS State Action Tracker—a living resource for HMAIS subscribers, which will be updated with federal and state-level details such as state-selected RHTP categories and award amounts.

Initiative Alignment and Partner Engagement: Common Themes Across States

As of early September 2025, at least 15 states have begun structured intake to inform initiatives and uses of the RHTP funding—requests for information (RFIs), surveys, town halls, webinars—with others maintaining a planning posture pending release of CMS’s application template.

Common themes and approaches emerging from these activities include:

  • Category-aligned input. States are encouraging stakeholders to align proposals with the statute’s eligible activities (e.g., access, outcomes, technology/prevention, partnerships, workforce, data/IT, solvency). Examples include:
    • Missouri requires submissions to identify which of the nine categories are addressed and to discuss outcomes and sustainability.
    • Delaware and Illinois use structured prompts to sort feedback by activity type.
  • Pre-guidance tools. States like Alaska, Montana, Mississippi and Oklahoma are using RFIs and statewide surveys to gather ideas and identify viable projects before CMS guidance is finalized.
  • Tech-enabled care. New and expanded uses of technology are topics of interest to states that are seeking ideas on how to maximize investments in remote monitoring, artificial intelligence (AI)/robotics, data/analytics, and IT/cybersecurity as eligible investments for improving access to services, healthcare delivery, and workforce support. For example:
    • Alaska explicitly references technology-enabled care models.
    • Oregon and Washington highlight health IT/cybersecurity and value-based purchasing.
  • Local coordination. States are encouraging regional partnerships/community hubs and rebalancing or right sizing service lines to match local demand. Missouri and Oklahoma emphasize right sizing service lines and coordinated care across the continuum of pre-hospital, emergency, acute inpatient, outpatient, and post-acute services. Oregon’s solicitation prioritizes regionally coordinated partnerships and explicitly calls out right sizing the care continuum as a focus area. North Dakota highlights strengthening partnerships between rural hospitals and other providers as a required component of the state plan.
  • Sustainability and value-based readiness. States are asking how projects will be sustained after federal funding ends and how these can support and sustain alternative payment models. Delaware and Missouri request implementation details and financial durability plans. Illinois prompts discussion of how proposals enable care coordination and payment reform.

Looking Ahead

The emerging national landscape for RHTP initiatives is mixed. Early state movers and their engaged partners are building momentum and reducing execution risk, while others are preserving flexibility until additional federal guidance arrives. States waiting on CMS’s template may face challenges in coordinating stakeholders and finalizing priorities before the application deadline.

For providers and community-based organizations (CBOs), now is a critical time to engage. These organizations are uniquely positioned to shape state applications by sharing on-the-ground insights, identifying unmet needs, and proposing scalable, sustainable solutions. Participating in state RFIs, surveys, and town halls allow providers and CBOs to inform how funding is prioritized and deployed.

To prepare for the RHTP resources and support, healthcare organizations should:

  • Monitor state-level engagement opportunities and respond to RFIs or surveys with clear, category-aligned proposals
  • Build or strengthen partnerships with other local organizations to demonstrate regional coordination
  • Assess internal capacity to implement and sustain projects beyond the federal funding window
  • Document outcomes and financial models that support long-term viability and alignment with value-based care

Connect with Us

To support transparency during this fast-moving period, HMAIS has launched the RHTP State Action Tracker, a centralized resource for curating each state’s actions, agency leads, deadlines, and links to official notices. The tracker will be updated as CMS guidance is released and as states fill in details, such as selected categories and award amounts. For details about the RHTP, including the HMAIS State Action Tracker, contact HMA experts below.

Webinar

Webinar Replay – Beyond Bundles: Preparing Hospitals for Success in TEAM and the Next Generation of Value-Based Models

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This webinar was held on September 30, 2025.

Hospitals and health systems are under growing pressure to succeed in new value-based models that demand both operational transformation and strategic alignment. In this webinar, advisors from Health Management Associates, Wakely, an HMA Company and Nixon Peabody broke down the latest regulatory and contractual developments, explored lessons learned from the Comprehensive Care for Joint Replacement (CJR) model, and discussed how organizations can prepare for upcoming opportunities.

Speakers shared practical insights on:

  • The regulatory, operational, and actuarial considerations hospitals must navigate
  • Key takeaways from bundled payment initiatives like CJR
  • How to leverage data and design strategies to build partnerships that position organizations for success in new Medicare models

This session was designed for hospital executives, provider organizations, payers, and policy leaders seeking to better understand how emerging value-based models will shape the future of care delivery and payment.

Featured Speaker:

Whitney Phelps, J.D., Partner Nixon Peabody

Webinar

Webinar Replay – Navigating Medicaid Managed Care Shifts: Financial Pressures, Federal Policy, and Medicaid MCO Implications

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This webinar was held on September 17, 2025.

Medicaid managed care organizations face mounting pressure as enrollment patterns shift, federal policy evolves, and state budgets tighten. In this webinar, experts from HMAIS, Wakely, and HMA shared exclusive analysis of Medicaid Managed Care Organization (MCO) financial performance, explored the implications of HR 1 and other federal policies, and offered State and MCO perspectives.

Learning Objectives

  • Interpret 2024 Medicaid MCO financial trends and historical benchmarks to anticipate future market performance.
  • Assess how federal policy changes, including HR 1, are reshaping Medicaid enrollment and creating new fiscal pressures for States and MCOs.
  • Evaluate state considerations around risk corridors, medical loss ratios (MLRs), and similar mechanisms in a challenging budget environment.
  • Identify strategies and planning initiatives that promote resilience, sustainability, and adaptation for Medicaid managed care organizations in a shifting landscape.

This webinar was for Medicaid managed care leaders, state officials, vendors, budget officers, and investors navigating financial pressures and policy shifts.

Blog

Federal Shifts and the Potential Impacts on Healthcare Quality Oversight

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This week, our In Focus section explores how recent federal shifts—particularly under the Trump Administration—are reshaping healthcare quality oversight. Health Management Associates (HMA) has published several analyses on the 2025 Budget Reconciliation Act (H.R. 1, formerly known as the One Big Beautiful Bill), Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), and the 2025 Centers for Medicare & Medicaid Services (CMS) Quality Conference. Together, these federal changes and the policy priority shifts described at the Quality Conference, have implications for monitoring and oversight of healthcare quality for publicly insured, commercially insured, and uninsured individuals.

In this article, HMA experts highlight potential areas for state Medicaid programs, healthcare organizations, and other industry partners to watch for as the rollout of new policies and programs begins to affect programs that monitor quality and creates the imperative to develop new oversight mechanisms.

Overview of Key Federal Policy Shifts

2025 Budget Reconciliation Act/H.R. 1

In July 2025, President Trump signed H.R. 1, the sweeping budget reconciliation legislation that directly affects publicly financed health coverage. Notable policy changes with quality implications include:

  • Mandatory six-month redetermination and community engagement for select populations
  • Stricter rules on healthcare-related provider taxes and state-directed payment policies
  • Elimination of Affordable Care Act (ACA) subsidy eligibility for certain lawfully present immigrants
  • An end to conditional eligibility for ACA subsidies, as well as passive re-enrollment
  • Required compliance with community engagement and work policies

Personal Responsibility and Work Opportunity Reconciliation Act of 1996

On July 10, 2025, the US Department of Health and Human Services (HHS) and other agencies, redefined “federal public benefits” to exclude individuals with “unsatisfactory immigration status” from certain healthcare programs. Examples include Certified Community Behavioral Health Clinics (CCBHCs), Community Health Centers/Federally Qualified Health Centers (FQHCs), grant-funded programs administered by the Substance Abuse and Mental Health Services Administration (SAMHSA), and Title X Family Planning.

2025 CMS Quality Conference

During the 2025 CMS Quality Conference, Centers for Medicare & Medicaid Services (CMS) Administrator Dr. Mehmet Oz and senior CMS officials, emphasized CMS’s and HHS’s evolving priorities under the Trump Administration. Notable priorities include empowering patients with data, reducing waste and tackling fraud, focusing on prevention, and transitioning to digital quality measures.

Quality Oversight Impacts

Key impacts on quality monitoring programs resulting from these federal changes and evolving priorities include:

Budget constraints elevate monitoring and value-based care metrics. Reduced Medicaid funding and tighter payment rules heighten the need for real-time monitoring of value-based care metrics to ensure financial sustainability in the changing market, optimize reimbursement.

Enrollment changes challenge quality tracking. Tighter eligibility and enrollment policies are expected to decrease enrollment in Medicaid (particularly among the adult expansion population) and the Affordable Care Act Marketplace program. Frequent redeterminations may cause coverage gaps and churn, distorting quality measure denominators and complicating performance tracking – especially for preventive and chronic care metrics.

Specifically, as the population mix in publicly funded programs changes or as gaps in enrollment exceed the 30‒45-day continuous enrollment criteria for many quality measures, the eligible population/denominators of quality measures will likewise fluctuate. Populations that lose coverage or churn on and off eligibility rolls can result in differential impacts for various quality measures (e.g., healthier individuals losing coverage affects prevention measures more than measures of chronic disease care).

Although performance on value-based care quality measures will have increased importance, the ability to track and trend performance will be increasingly challenging. Healthcare organizations will benefit from forecasting potential changes to patient mix and volume and real-time monitoring and improvement opportunities.

Rise in uncompensated care requires new quality monitoring. H.R. 1 changes that reduce eligibility, paired with PRWORA changes that limit treatment for certain individuals who receive public benefits, are likely to lead to increases in the uninsured population and inhibit access to preventive care. These populations tend to use emergency departments more often for health issues that could have been treated earlier or more effectively in outpatient settings, yet quality oversight is limited for populations that receive care outside of publicly or commercially funded programs. New mechanisms for quality oversight—and funding of those mechanisms—will be needed to monitor the health of these populations.

New programs and priorities warrant updated monitoring. H.R. 1’s Rural Health Transformation Program and CMS’s dual-track quality measurement approach (“treating illness” versus “maintaining health”) necessitate a reevaluation of current metrics and monitoring systems.

Implementation of digital quality measures will support these efforts when fully implemented. The accelerated movement toward digital quality measurement and interoperability may create an imperative for healthcare organizations to make the shift. For example, the transition to digital quality measures will be necessary to ensure real-time oversight and improvement of quality measures, population health analytics, maximizing value-based care payments and efficiencies needed to effectively respond to federal changes. At the same time, healthcare organizations will need strategies to effectively deploy digital quality and interoperability within and across their organizations to not just comply, but to maximize their capabilities.

Connect with Us

HMA works with state agencies, payers, health systems, and providers to assess and implement quality systems, value-based care programs, performance improvement and digital health. To discuss how federal changes will affect your organization’s quality programs, contact our featured experts below.

Podcasts

What Should Quality in Healthcare Really Mean Today?

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Quality is a word we all use in healthcare, but what does it truly mean for patients, clinicians, and systems striving to improve care? In this episode of Vital Viewpoints on Healthcare, Sarah Hudson Scholle, Principal at Leavitt Partners, an HMA company, and a nationally recognized expert in healthcare quality unpacks how quality has been defined and measured over the years, why measurement sometimes gets in the way of improvement, and how digital interoperability will more accurately capture true drivers of quality. Sarah also shares why engaging patients in defining their goals and outcomes is essential to creating measures that reflect what really matters in people’s lives.

Case Study

Applied Behavior Analysis (ABA) Auditing Services 

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THE CLIENT

HMA’s team of expert behavioral health auditors from Crestline Advisors performs audits of behavioral health services, including applied behavior analysis (ABA) services, for a Medicaid health plan in Virginia (“the client”). The client refers cases to HMA when there are allegations of possible fraud, waste, or abuse (FWA) concerning documentation and/or billing practices for these services.

BACKGROUND

ABA is an evidence-based behavior therapy for people with autism spectrum disorder (ASD) and other developmental disorders. In recent years, the diagnosis of ASD and subsequent demand for ABA services has increased. State Medicaid administrations and Managed Care Organizations (MCOs) are tracking increased ABA utilization and wait times for these services, and in some situations are investigating quality of care and/or FWA concerns. Types of FWA concerning ABA therapy services may include billing for services not rendered, billing for ABA services without documentation of ABA-specific interventions, billing for services by unqualified individuals, or billing more units than the documentation supports, to name a few. We have a deep bench of licensed behavioral health clinicians and coders with many years of experience in conducting audits for MCOs, state Medicaid administrations, and providers. Given our expertise, we understand the importance of the golden thread of documentation that should underlie billing, including assessments and treatment plans which identify the need for ABA services and documentation of ABA service interventions, supervision, and family training.

APPROACH

The client’s SIU team identifies providers of ABA services for whom there is an allegation of potential FWA and provides us with sample claims and medical records to review. We have developed customized audit tools to investigate the unique documentation and billing considerations for ABA. Incorporating state-specific provider/billing manual requirements, we conduct pre- and post-pay audits in which we may identify errors in documentation (misalignment with what is billed on the claim). We then provide a detailed report to the client summarizing the identified errors and potential improper payments. Our team also can assist in the pre-audit phase to develop provider communications to request medical records and provides post-audit support to MCOs to help explain findings to providers impacted by the audit, or to support the MCO in an appeal or fair hearing process.

RESULTS

This is an ongoing project that has already provided significant value to our client in a short period of time. The client’s analysis of our auditing work, which included ABA findings reports as well as findings reports for other behavioral health services, has already identified a 12:1 return on investment, based on associated recoupment of improper payments and estimated prevented loss. Our own internal ROI analysis, focused specifically on ABA audits, also identified a 12:1 benefit. By working with our team, MCOs can expect to see timely and thorough identification of potential improper payments upon which they may act to reduce FWA. Ultimately, reducing FWA leads to increased availability of services for the members who need them most and promotes improved quality of care from qualified professionals. To learn more, email Shannon Walters.

Brief & Report

Medicaid Coverage of Breastfeeding Support and Supplies

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This report presents an independent landscape analysis by Health Management Associates (HMA) examining Medicaid coverage of breastfeeding services and supplies in six states: Arkansas, Colorado, Kansas, North Carolina, Oregon, and Vermont. The analysis explores the availability and implementation of lactation consultation services and breast pump benefits within these state Medicaid programs, based on policy reviews and interviews with key stakeholders. Participants included state Medicaid officials, WIC representatives, lactation providers, managed care organizations, community-based organizations, and breastfeeding experts.

Findings reveal persistent barriers to access, inconsistencies in policy execution, and implementation gaps. The report highlights effective practices currently in use and offers targeted policy recommendations to enhance service delivery, promote equitable access, and improve maternal and infant health outcomes. This analysis serves as a strategic resource for stakeholders seeking to strengthen Medicaid’s role in supporting breastfeeding families.

Blog

Building Rural Health Together: Reflections from the Ohio Rural Health Association Conference

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Earlier this month colleagues from Health Management Associates (HMA) attended the 2025 Ohio Rural Health Association Conference. The gathering brought together providers, policymakers, and advocates from across the state to discuss one of the most pressing issues of our time: the future of rural health care in an uncertain policy and financial environment.

At a moment when federal funding and regulatory debates dominate the headlines, what stood out most was the energy and commitment among local leaders to work together on practical solutions. The challenges facing rural communities are profound—hospitals and clinics strained by reimbursement shortfalls, workforce shortages threatening access, and shifting payer dynamics creating new administrative burdens. Yet the conversations throughout the conference were grounded in resilience and collaboration, demonstrating that sustainable solutions begin at the community level.

Spotlight on Collaboration

HMA was honored to contribute to this dialogue through three sessions focused on core issues shaping rural care.

  • Kenneth Cochran, DSc, RN, FACHE, drew on his deep leadership experience as a former Ohio hospital CEO to highlight the urgency of workforce development. With projections of a 187,000-physician shortfall by 2037, Ken outlined integrated workforce strategies—apprenticeships, housing partnerships, and a culture of continuous learning—that can help stabilize rural hospitals and strengthen community health infrastructure.
  • Courtney Smith, RHIT, CCS, shared two critical perspectives. First, she unpacked the growing strain of Medicare Advantage in rural communities, where reimbursement often falls short and administrative requirements delay patient care. Second, she explored the complexities of Medicaid revenue cycle management, offering actionable steps rural providers can take—from leveraging technology and analytics to streamlining wrap-around payment reconciliation—to maintain stability in an unpredictable environment.
  • Jennifer Shaw, Senior Consultant, co-presented on best practices for navigating payer relationships with Courtney. She underscored how rural providers can use data to strengthen negotiations and how collaboration across hospitals, clinics, and associations creates the leverage necessary to ensure fair treatment in contracting and payment.

These discussions demonstrated the value of having clinical, operational, and policy perspectives at the table. Each HMA colleague brought not only technical expertise but also a deep appreciation for the lived realities of rural providers, ensuring our sessions were rooted in practicality.

A Landscape in Flux

The national policy context reinforces the importance of this work. Recent debates in Washington over rural health funding underscore just how fragile the financial footing of many hospitals and clinics can be. While the outcome of federal policy is uncertain, what is clear is that communities cannot afford to wait.

As HMA has noted in our broader work on rural health, effective solutions hinge on collaboration across sectors and levels of government. Whether it’s building workforce pipelines, ensuring fair payment, or streamlining operations, progress requires alignment among providers, payers, policymakers, and communities themselves.

Moving Forward

The Ohio Rural Health Association conference was a reminder that even in uncertain times, there is a powerful foundation for innovation and problem-solving when rural providers work together. HMA is proud to support these efforts, bringing decades of experience in Medicaid policy, health system transformation, and rural health strategy to bear for our partners.

As we look ahead, one lesson stands out: the path forward for rural health will not be written in Washington alone. It will be forged in places like Ohio, where providers, leaders, and communities are building practical, collaborative solutions every day.

Ohio Health Policy Snapshots

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Blog

Executive Order Addressing Homelessness: The Federal Shift Toward Institutionalization

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President Trump signed an executive order (EO), Ending Crime and Disorder on America’s Streets, on July 24, 2025, signaling a significant shift in federal homelessness policy and the requirements for organizations that use federal dollars to address homelessness in their communities. The order emphasizes public safety and prioritizes institutionalization and mandatory treatment over housing first approaches.

The administration asserts that “the overwhelming majority of these individuals are addicted to drugs, have a mental health condition, or both” and calls for transitioning homeless individuals into long-term institutional settings through civil commitment for “humane treatment.” Below, Health Management Associates (HMA) outlines key elements of the EO, including provisions, key stakeholder considerations, and potential strategies to maintain care continuity amid federal changes.

Key Elements of the Executive Order

End of Housing First: The EO discontinues support for the Housing First model, directing federal agencies to prioritize mandatory treatment. The Department of Housing and Urban Development (HUD) Secretary is directed to take steps requiring treatment participation as a condition of HUD program participation.

Support for Civil Commitment Infrastructure: The federal government will assist state and local governments with technical guidance, grants, and other resources to implement civil commitment, institutional treatment, and step-down treatment standards. The Attorney General and US Department of Health and Human Services (HHS) Secretary are instructed to pursue reversal of legal precedents that restrict civil commitments for individuals with mental illness who pose risks or are unable to care for themselves.

Restructuring Federal Programs: The EO directs HHS, HUD, and the Departments of Justice (DOJ) and Transportation (DOT) to review discretionary grants and restructure programs to ensure compliance with the new guidelines, as outlined below.

  • HHS Substance Abuse and Mental Health Services Administration (SAMHSA) grants will no longer support harm reduction or safe consumption efforts and has issued a “Dear Colleague” letter clarifying which services will be funded; for example, naloxone distribution can be funded, but clean syringe distribution cannot.
  • HUD will exclusively, where permissible, fund programs for women and children and revise regulations to exclude registered sex offenders.
  • Some emergency law enforcement funds may be allocated for encampment removals.

Expanded Roles: The EO directs HHS to leverage the use of federally qualified health centers (FQHCs) and Certified Community Behavioral Health Clinics (CCBHCs) to reduce homelessness and ensure federal funds support crisis intervention and comprehensive behavioral health services. In addition, the Attorney General is directed to prioritize funding for the expansion of drug and mental health courts.

Notably, federal grants will prioritize jurisdictions and states that enforce laws against open drug use, urban camping, urban loitering, and urban squatting. Grant recipients must also share certain health-related data with law enforcement, as permitted by law.

Considerations for Stakeholders

States, local governments, and county jurisdictions must assess housing and homeless programs that use federal funding streams. They must consider the implications of their current program activities and, where possible, realign programs with new requirements. They may gain access to new funding for treatment beds, drug and mental health courts, crisis response, and law enforcement support but risk losing funding for those programs that use harm reduction or housing first models. Local governments could face increased jail overcrowding and legal challenges related to civil commitments and data sharing. Early examination of current programs, particularly HUD and crisis programs, as well as early planning, will be essential.

Providers may need to restructure services to comply with the new mandates, including collaboration with crisis/removal entities and law enforcement and expanded reporting. Emergency department and inpatient facilities may see increased demand, especially from uninsured individuals.

State behavioral health authorities and other stakeholders can benefit from forming advisory councils to develop ethical frameworks for civil commitments, as well as consider providing training for providers and law enforcement and propose revisions to state statutes and regulations

Homeless individuals are likely to experience increased policing, institutionalization, and loss of access to non-mandated services and housing.

What Happens Next

Federal agencies are now responsible for implementing the EO, revising grant programs, issuing guidance, and shifting funding priorities toward enforcement and institutional treatment. These changes will redefine compliance for local governments and service providers.​

Health and housing organizations must quickly assess the implications of this policy shift. Strategic collaboration across sectors, including behavioral health, housing, law enforcement and judicial systems, will be essential to maintain care continuity and protect individual rights.

Connect with Us

HMA’s housing and homelessness and behavioral health experts are closely monitoring the evolving federal policy landscape and legal developments. We are tracking federal funding shifts, priorities, and opportunities across HHS, HUD, DOJ, and DOT, helping stakeholders align their programs with new priorities to enhance eligibility and impact.

For details about federal agency implementation of the EO and downstream effects, contact our featured experts below.

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