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Empowering clients to advance policies and system redesign for youth and families

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The current youth behavioral health system is under-resourced, underfunded and often not well coordinated. Historic approaches that minimally adapt adult models to children and youth have led to insufficient child and youth specific strategic design of effective systems. Recent investments and policies offer a tremendous opportunity to redesign strategies, payment, and the delivery system to enhance access and achieve better outcomes, equity, and satisfaction of children and families. Health Management Associates (HMA) understand the levers and impacts across the system from state and local policy makers to payers, providers, schools, and communities. Our multidisciplinary teams will partner with you to identify challenges and solutions to advance and sustain the system of care.

What Makes HMA Unique?

HMA’s cross sectoral, multidisciplinary team is comprised of more than 20 dedicated children and youth behavioral health experts with rich backgrounds in government, community-based providers and payers. Our approach includes a deep understanding of policy, clinical, operations and fiscal systems, providing our clients with fundamental tools to design and implement sustainable solutions.

Our expertise spans multiple specialty areas impacted by children’s behavioral health:

Juvenile justice and justice-involved

Child welfare and foster care

Children’s behavioral health – primary care and social services, children with serious behavioral health issues (SMI, including co-occurring issues)

Youth crisis and mobile services, crisis stabilization unit design (CSU) services

School-based wellness centers, community schools

Certified community behavioral health clinics (CCBHCs)

Suicide prevention

State policy and system redesign, evidence-based practices and strategic planning including the intersection of Medicaid and child welfare

Telehealth for children and adolescents

Tech-enabled care

Mental health first aid

Our team is advancing the design, integration, and quality of children’s behavioral health across states and the continuum of care.

Examples of our work include:

Policy and system design for behavioral health services, foster care, and the intersection of Medicaid and child welfare

Maternal and child health programing and 2Gen approaches

Managed Care Organizations (MCO) reviews, strategy ad program design

Health system emergency department boarding and health system and community intervention design

Mobile Crisis Response (MCR) design and implementation

Implementation of school-based wellness centers and building connections to the health system

Services across the healthcare spectrum.

With a deep understanding of current and emerging shifts in care and policy, our behavioral health consultants are well equipped to provide specialized services for a range of clients.

Our Clients


Bolstering the youth behavioral health system: innovative state policies to address access & parity

This week, our In Focus section highlights an HMA Issue Brief, Bolstering the Youth Behavioral Health System: Innovative State Policies to …

Innovative state policy solutions to enhance the youth behavioral health system

With suicide now the second leading cause of death among children, adolescents, and young adults (aged 15-24 years old) in …

Meet some of our behavioral health experts:

Uma Ahluwalia

Uma Ahluwalia

Managing Principal

Uma Ahluwalia is a respected healthcare and human services professional with extensive experience leading key growth initiatives in demanding political … Read more
Heidi Arthur

Heidi Arthur


Heidi Arthur has over 20 years of experience in delivery system redesign to promote community-based access to health and human … Read more
Michael Butler

Michael Butler

Associate Principal

During his career, Michael Butler has directed hundreds of program evaluation, organizational development, and technical assistance projects in a wide … Read more
Gina Lasky

Gina Lasky

Senior Advisor

Gina Lasky is a licensed psychologist with expertise in public sector behavioral health system design and programming including integration of … Read more

Behavioral health workforce: an ongoing crisis 

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Mental health and substance use treatment organizations struggle to meet the increase in demand for services, due in large part to a national workforce shortage. This challenge has been exacerbated due to the Covid-19 pandemic. Demand for behavioral health organizations’ services has continued to increase. At the same time, organizations are having trouble recruiting and retaining employees, and patient waitlists continue to grow. Competition for behavioral health workforce has only grown with new opportunities in telehealth and the entrance of private equity into the behavioral health market. The safety net providers are the most impacted and often have the least flexibility to address underlying factors leading to the shortages in large part due to regulation and administrative burden and underfunded payment models.   

HMA, in partnership with the National Council for Mental Wellbeing (NatCon), developed a series of issue briefs outlining state policy and provider steps that can help to address the critical shortage.

HMA is also working with NatCon and the College for Behavioral Health Leadership (CBHL) to engage national partners using a collective impact framework to provide backbone support for organizations to work together in a more structured and action-oriented approach and to leverage various implementers (policy, regulatory, payers, providers, educators, etc.) to move recommendations to action.   

Behavioral Health Workforce is a National Crisis: Immediate Policy Actions for States 

View Issue Brief

Actions to Address the National Workforce Shortage and Improve Care

View Issue Brief

Diversity, Equity and Inclusion: Emerging Opportunities for the Behavioral Health Workforce 

View Issue Brief

HMA can help state policy makers and provider organizations with workforce support and problem solving, workforce assessment, strategy and policy design.

Our team of experts includes clinicians with on-the-ground experience as well as previous policy makers. We’ve worked within the certified community behavioral health clinic (CCBHC) model and provide technical assistance to organizations planning for its adoption. We have experience in extending it beyond the demonstration utilizing Medicaid state plan amendments (SPA) or 1115 waivers to enhance the workforce.

HMA capabilities

Identifying effective workforce strategies including training and maximizing of multi-disciplinary teams (e.g., peers, behavioral health providers, nurses, licensed health care providers). 

Policy and system design for behavioral health services and workforce expansion 

Managed Care Organizations (MCO) strategy and program design as well as strategies to enhance the provider network 

Conducting certified community behavioral health clinic (CCBHC) readiness and implementation support. 

Maximizing virtual and technology interventions. 

Convening stakeholders and building partnerships across sectors. 

HMA is positioned to support

State Medicaid agencies 

State and local departments of health, public health, behavioral health, and child welfare 

Health plans & Managed Care Organizations  

Hospitals & health systems  

Provider organizations 

Community-based organizations  

Foundations & advocacy organizations

Certified community behavioral health clinics 

School-based behavioral health

Correctional health & juvenile justice systems 

Contact our experts:

Paul Fleissner

Paul Fleissner

Managing Principal

Working to integrate services across systems and communities, Paul Fleissner is a seasoned executive who has developed programs and policies … Read more
Allie Franklin

Allie Franklin

Managing Director

Allie Franklin is a licensed clinical social worker with decades of experience in public, private, and non-profit behavioral health, healthcare, … Read more
Gina Lasky

Gina Lasky

Senior Advisor

Gina Lasky is a licensed psychologist with expertise in public sector behavioral health system design and programming including integration of … Read more

Creating crisis systems that work

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With the planning and implementation of 988 and mobile crisis teams, as well as co-responder models, state policy makers are working rapidly to advance effective approaches to systemically and effectively address the needs of individuals and families who are experiencing behavioral health crises.

Central to effective implementation is attention to specific community needs. States are working to partner with local communities to build capacity, leverage the knowledge and expertise of local partners, and gain an understanding of how new benefits and system changes fit into existing community frameworks. This local approach is particularly important for rural and frontier communities, and for tailoring models to meet specific priority populations’ needs, while building trust and ensuring crisis services are grounded in equitable access and culturally responsive care.

With more than 25 years of crisis system development, HMA colleagues stand ready to support crisis system community partners in advancing their crisis systems and services.

With our finger on the pulse of the science-backed research and approaches necessary to create integrated and comprehensive systems, we can help identify barriers and explore and implement solutions.

Our HMA crisis system team supports community partners with:

Partnership development

Stakeholder engagement

Crisis system needs assessment – strengths and gaps analysis

Program design and implementation

Crisis service development

Cross-system protocols

Cost modeling and sustainable reimbursement approaches

Distilling and meeting regulations

Contact our experts:

Suzanne Rabideau

Suzanne Rabideau


A transformational health and human services leader, Suzanne Rabideau has more than 25 years of experience working with, and inspiring … Read more
John Volpe

John Volpe


John Volpe is an experienced senior health official with a demonstrated record of success at the intersection of health, social … Read more

Policy changes in Medicare Advantage and the implications for coding, risk adjustment, and reimbursement

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On Tuesday, April 11, 2023, HMA hosted a Future Frame Conversation covering some of the changes outlined in the recent 2024 Medicare Advantage (MA) Rate Announcement. This cycle signals a new era for MA funding and risk adjustment. The Final Rate Announcement, in particular the new risk adjustment model to be phased in over three years, will spark stakeholders to reevaluate benefit design through the bid cycle and risk adjustment strategies in the future. These refinements will impact both health plan and provider reimbursement. 

During the discussion:

  • Amy Bassano from HMA talked about the CMS strategy for these changes;
  • Tim Murray from Wakely Consulting, an HMA company, discussed how payers should be using data and analytics to evaluate and forecast the impact of CMS changes; and
  • Todd Husty from MARSI, an HMA company, talked about deployment of audit tools to assess documentation, coding practices, and risk adjustment policies.

Click here to view referenced Wakely white papers mentioned in this recording.


Public health after the emergency ends

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Policy crossroads and the end of the public health emergency due to COVID-19

This is part of a three-part series on significant implications of the end of the Public Health Emergency (PHE). 

The Biden administration has announced that the COVID-19 pandemic Public Health Emergency (PHE) declaration will expire on May 11, 2023. The end of the declaration and other changes in federal policy have significant implications for state Medicaid programs, including the end of a 6.2% increase in the regular federal medical assistance program (FMAP) matching rate for states and continuous enrollment requirements put into place early in the pandemic. This means that an estimated 4-14 million Americans, especially including women and children, will need to engage in state processes for re-certification to continue their Medicaid benefits and states will lose their enhanced matching.

While state have been planning for these changes, collectively referred to as “PHE Unwinding,” the public health implications of these shifts have received little attention. As millions of Americans lose Medicaid benefits, as a result of “PHE Unwinding,” public health departments nationwide are likely to face additional demands and pressures that are also critically important for states to consider. State public health agencies that have spent the last several years responding to the COVID-19 pandemic are now entering a new phase. During the CMS-recommended 12-month period that states have to complete their redeterminations, public health agencies may see increasing numbers of individuals who were previously eligible for Medicaid and other safety net services seeking access to public health programs. Public health officials also may be called on to address the community health impacts of the newly uninsured or those who have lost other benefits, such as enhanced Supplemental Nutrition Assistance Program (SNAP) dollars for food. Addressing challenges may require significant attention of Community Health Workers or other workforces engaged across public health and healthcare and take precedence over other public health priorities. All of this will be happening at a time when public health officials are being called on to re-imagine their infrastructure needs, including reconfiguring and modernizing their data systems.

Public health agencies planning for this immediate future may benefit by taking a systems approach to PHE unwinding and considering a few key variables in their planning—

1.The end of the PHE may rapidly increase demand for public health safety net programs.

Medicaid provides coverage for the sickest and most vulnerable. As redetermination processes leave some without insurance and other benefit programs like SNAP return to pre-pandemic coverage, historically marginalized and medically at-risk populations will be disproportionately impacted. This may result in increased demand for safety net programs usually found in public health departments that serve the under and uninsured, such as the Breast and Cervical Cancer Prevention Program (BCCP) that provides cancer screening for women, and Vaccines for Children (VFC) which provides required immunizations to school-age children who otherwise lack access. Programs such as the Women, Infants and Children (WIC) and perinatal home visiting programs that serve families with limited economic resources may also see increased numbers of eligible families. Health departments can quantify these increases by assessing their populations, estimating increases, and using their existing data to determine which communities and geographic areas are likely to exhibit the greatest needs, and then share this information with policymakers.

2. Unwinding may represent an opportunity to educate legislators and policymakers on the connection between Medicaid utilization and public health programs.

As states see decreases in federal matching for their Medicaid programs, policymakers will look for opportunities to fill gaps in the state share of operating these programs. Public health programs, which are usually run with a combination of state dollars and federal grants, are often looked at as potential sources to fill gaps in Medicaid program costs. Moreover, public health officials may be able to move upstream of these discussions by ensuring that states are maximizing the federal Medicaid match (FMAP) on any public health services that can be billed to Medicaid, including using waivers and state plan amendments to cover services such as maternal home visiting or tobacco cessation under Medicaid, thus stretching grant and state dollars further while covering more individuals. While public health has long discussed the benefits of calculating and sharing the long-term return on investment of public health services, officials may also wish to consider utilizing risk stratification strategies to identify short-term cost savings and cost avoidance to other state programs of the services offered by public health departments. At the local level, health departments are often closely involved in the delivery of services that keep children in school, adults at work, and protect people in hospitals and nursing homes from health care acquired infections. All of these services have immediate benefits to state and local economies.

3. New funding for public health infrastructure, data modernization, and workforce development represents an opportunity to drive collaboration between public health, Medicaid, and other sectors.

As a part of the American Rescue Plan, state public health agencies have received funding from CDC to strengthen their infrastructure to ensure that communities have the people, services, and systems to promote and protect public health. The grants are intended to allow states to focus on increasing the size and diversity of the public health workforce; modernize data systems; and ensure states can demonstrate the foundational capabilities of public health. CDC has affirmed its expectation that states will prioritize collaboration and organizational partnerships as part of these efforts. As state public health agencies use these federal investments to impact programs that reach priority populations and improve health outcomes, several opportunities to reach disadvantaged populations and improve their health outcomes become apparent. For example, public health agencies working collaboratively with state departments of education could lead to partnerships around school-based clinics or workforce training programs, while engaging with the private healthcare and laboratory sectors on data and disease surveillance seems promising. Health departments should start now to in preparation for the flurry of activity that will be sparked in the wake of the PHE. This might involve reaching out to potential partners or organizing town-hall-style” active listening sessions with citizens to meet people where they are and better understand the needs of the community they serve.

HMA and HMA companies will continue to analyze the public health implications of the Medicaid Unwinding and the end of the PHE. We have the depth and breadth of expertise to assist with capacity building, data collection and management, and population health analysis.

If you have questions on how HMA can support your agency before or after the end of the PHE, please contact:

Jean O’Connor, Managing Principal
Morgan Wilson, Research Associate


Florida releases Medicaid Managed Care ITN

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This week our In Focus section reviews the Florida Statewide Medicaid Managed Care Program (SMMC) Invitation to Negotiate (ITN), released on April 11, 2023, by the Florida Agency for Health Care Administration (AHCA). SMMC consists of three programs: Managed Medical Assistance (MMA), Long-term Care (LTC), and dental, covering 4.4 million individuals. This ITN is for contracts to provide MMA and LTC.

Under the SMMC program, all enrollees receive their services from a single plan providing managed medical assistance, long-term care, and specialty benefits. (Dental benefits are provided separately.)

AHCA will select plans that will achieve the agency’s goals, including providing healthy birth outcomes for mothers and their infants, improving childhood and adolescent mental health, maximizing home and community-based placement and services, and supporting the HOPE Florida program. HOPE Florida utilizes ‘Hope Navigators’ to help individuals achieve economic self-sufficiency, develop long term-goals, and map out a strategic plan by focusing on community collaboration between the private sector, faith-based community, nonprofits and government entities.

Additionally, with the new contracts, AHCA will implement the following changes:

  • Specialty plans will no longer be awarded separately but must be awarded to a comprehensive or MMA plan.
  • Enrolling voluntary recipients (such as individuals with intellectual or developmental disabilities) into the SMMC program and providing the opportunity for them to opt out
  • AHCA may mandatorily enroll into the MMA program full benefit dual-eligibles who are also in a Medicare Dual Eligible Special Needs Plan (DSNP).

AHCA will invite 10 plans to negotiate for awards as shown below:


Proposals are due August 15, 2023, with an anticipated award date of December 11. Contract will run from October 1, 2024, through December 31, 2030. Contracts may not be renewed, but AHCA may extend the term to cover any delays during the transition to a new plan.


Plans can receive a total maximum number of points of 5,950. AHCA will invite top-ranking plans to negotiations to ensure that AHCA can enter into contracts with the minimum required number of plans per region.

Current Market

As of December 2022, Florida served 4.3 million MMA and LTC enrollees, excluding an additional 97,000 Children’s Medical Services enrollees in the Children’s Medical Services Network plan. Centene had the highest market share based on enrollment, at over 40 percent.

Link to ITN

Case Study

Learning collaborative for implementation of medications for addiction treatment (MAT) in county criminal justice systems


HMA and the California (CA) Department of Health Care Services (CDHCS) are collaborating to expand access to at least two forms of MAT in CA county jails and drug courts in a statewide learning collaborative with technical assistance (TA) and provider coaching. Multidisciplinary teams from 34 counties are participating in the learning collaborative and demonstrating success in rapidly increasing access to MAT in jails and drug courts.

Intro and challenge

The California Jail MAT Expansion Project elevates jails as a key part of the safety net for addictions treatment by bringing together teams in each county that include stakeholders in county justice and substance use disorder system of care, centered on the jail and with each County sheriff as the lead sponsor. Teams have access to shared learning activities and ongoing individualized technical assistance and coaching from HMA subject matter experts (SMEs).

The project launched in May of 2018 when teams were invited and the first 22 teams were convened in August of 2018 in person in this large, statewide initiative designed to dramatically change the treatment landscape in jails and drug courts.

In undertaking this transformation HMA coaches and SMEs must understand and respond to the unique regulatory oversight, policies, and procedures in jail operations requiring customized approaches to introduce and expand MAT inside the jail. Both adaptive and technical change strategies are deployed to assist jails in changing their culture and operations to treat substance use disorder (SUD) like other chronic, treatable diseases. HMA coaches and SMEs stay deeply involved with county teams to initiate and support change over time.

There are now 34 participating teams and the data reported from 22 teams as of June 2021 confirms they had provided MAT to almost 15,000 individuals while in custody. When the project began in September 2018 less than 25 people were receiving MAT while incarcerated in the 22 initial participating counties.


Teams are required to submit an application to participate in the learning collaborative that includes information about the current state of MAT in their jail and drug court. This information is supplemented by calls with their assigned HMA coach to further understand their current operations, resource capacity, and goals. All county teams are convened for a collaborative learning session to “jump start” their implementation plan. This session includes fundamental information on MAT and related components of evidence-based substance use disorder treatment in jails and justice settings. On an ongoing basis each team is assisted by their coach to establish and execute goals and action steps

that align with the overarching goals of the learning collaborative. Coaches identify challenges and barriers at their sites and these themes inform ongoing webinar trainings and sessions at additional learning collaborative convenings. Bringing together a cohort of county teams provides an opportunity to understand at a broad scale the state of MAT in California jails and design targeted interventions to accelerate their implementation of MAT. Broad themes, such as biases against MAT among providers and custody staff; custody concerns about diversion of medications; and payment mechanisms for the medications and sufficient staff capacity to offer the treatment arise across the cohort and are subsequently targeted with training and hands-on coaching support. This ongoing collection of information from counties and close contact with teams and the HMA Team’s clinical expertise inform the unique approaches at each location.

Critical elements of the change effort include:

  • Improved SUD screening, assessment, treatment options and planning to include at least two forms of MAT are core themes and goals of the learning collaborative. This messaging and expectation accelerate implementation by “setting a bar” for teams’ efforts while providing them with individualized assistance to overcome challenges in meeting their goals.
  • Engagement across the treatment ecosystem in the county including advisors from state associations of counties, sheriff departments, treatment providers, and the state prison system connects the counties with emerging policy and best practice from their professional peers.
  • Multidisciplinary teams: MAT in jails and drug courts requires an integrated approach inclusive of medical and behavioral health care staff, custody/security and other justice professionals, and county providers and leadership

This implementation model drives rapid, systemic change that would likely not be possible with individual county efforts. Scaling is accelerated by the learning collaborative model in which barriers that are identified by multiple county teams, such as regulations for methadone in the jail, or practice of a healthcare vendor serving multiple sites, are addressed at the levels of state policy or corporate leadership and addressed in group learning opportunities.

Lessons Learned

  • The approach has to be tailored for each jail. Each jail and county have resources, concerns, and goals unique to them and the technical assistance must incorporate this understanding and meet them where they are to be effective.
  • The aim – improved SUD treatment systemwide – including transitions when individuals enter the corrections system and again at release – needs to be addressed as a countywide problem that needs a countywide solution.
  • Implementation of MAT in jails should be sponsored by the Sheriff and key partners from probation, jail custody, jail healthcare, drug courts, local county drug treatment programs, and the county administrator’s office must be included in planning and implementation.
  • Do not underestimate the prevalence and impact of stigma. There is an ongoing need for broader education about addictions treatment including Probation and parole, judges and district attorneys, the community, children’s and family services, and even community providers and the self-help support community need to understand MAT as treatment, and more specifically, not as ongoing substance use that is construed as problematic.
  • Do not go too fast: it is important to build supportable, sustainable implementation If teams are not given sufficient support and opportunity to evolve in their understanding and development of the implementation program they may fail. At the same time a sense of urgency is important because people are dying due to lack of access to needed treatment.

Key Successes/Outcomes

  • As of June 2021, almost 15,000 individuals in jail in California have received MAT during their period of incarceration. About one third of those were initiated on MAT while in jail and others that had been receiving MAT in the community were continued on their customary dose when incarcerated. At the inception of the learning collaborative initiative in September 2018 the initial 22 participating county jail teams reported a total of less than 25 people who were receiving MAT while incarcerated. After one year of participation in the learning collaborative counties reported that 1,646 detainees had received MAT in custody, and 678 were in-custody initiation of treatment with buprenorphine. This represents rapid implementation and scaling driven by the learning collaborative model.
  • All participating jails now provide naloxone to individuals with opioid use disorder (OUD) on release, a critical element to protect the safety of those individuals post release.
  • The program was so successful the state awarded additional funding to maintain the 1st cohort and fund additional teams in 2020 and 2021. There are currently 34 counties participating that collectively represent 86% of the population of The project model has been replicated in 16 counties in 15 states in a national initiative with Arnold Ventures and the Bureau of Justice Administration; and in the states of Pennsylvania and Illinois.

Download the full case study:


Medicare Advantage Capitation Rates and Part C and Part D Payment Policies

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This week, our In Focus section reviews the recently announced major policy updates from the Centers for Medicare and Medicaid Services (CMS) that affect the Medicare Advantage (MA) and Part D programs.

First, on January 30, CMS released the final Risk Adjustment Data Validation Final Rule, a highly anticipated and controversial policy that establishes the agency’s approach to auditing MA Organizations’ (MAOs) risk-adjustment payments and collecting overpayments as needed. Second, CMS released the CY 2024 Advance Notice for MA Capitation Rates (Part C) and Part D Payment Policies on February 1, 2023. HMA’s summary of the advance notice is available here.

Most recently, on March 31, 2023, CMS released the CY 2024 Final Rate Notice for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies, which incorporates CMS’s responses to public comments on the Advance Notice. These changes reflect CMS’ continued efforts to strengthen oversight in the MA program, including improving payment accuracy, and implementation of Part D policies from the Inflation Reduction Act (IRA).

Below are highlights of some of the key provisions of the CY 2024 Final Rate Notice and significant changes CMS made from the Advance Notice to the Final Rate Notice.

Risk Adjustment: The Final Rate Notice details the updated risk adjustment model using restructured condition categories based on ICD-10 codes, newer data, and clinical adjustments made to ensure the conditions are stable predictors of costs in the model. Specifically, diagnoses data will come from 2018 rather than 2014 and expenditure data will come from 2019 rather than 2015 to reflect changes in costs. These updates should more accurately reflect the cost of caring for beneficiaries and make payments less susceptible to discretionary coding that can lead to excess payments to MA plans.

Also, CMS changed course from its initial proposal in the Advance Notice to implement the above risk adjustment model changes fully in 2024, and instead decided to phase in these changes over three years. The updated risk adjustment policy will be phased in over three years for organizations other than PACE. As a part of the agency’s phase-in plan, 67 percent of the CY 2024 risk adjustment will come from the risk scores measured under the 2020 adjustments and 33 percent will come from the 2024 adjustments. In CY 2025, 67 percent of the risk adjustment will come from the 2024 adjustment. In 2026, 100 percent of the risk adjustment will come from the 2024 adjustment. For PACE organizations in CY 2024, CMS will continue to use the 2017 risk adjustment model and associated frailty factors to calculate risk scores.

Effective Growth Rate: The effective growth rate identified within the Final Rate Notice for CY 2024 is 2.28%, up from 2.09% in the Advance Notice. The Effective Growth Rate is largely driven by growth in Medicare Fee-for-Service expenditures. CMS will phase in a technical adjustment to remove MA-related indirect medical education and direct graduate education costs from the historical and projected expenditures.  The technical adjustment to the Effective Growth Rate will be phased in over three years, where 33 percent of the adjustment will apply in CY 2024, 67 percent in CY 2025, and 100 percent in CY 2026.

Payment rate impact in MA: CMS expects that average payments to MAOs will increase by 3.32 percent in CY 2024 because of the finalized rate announcement, which is higher than the 1.03 percent increase outlined in the Advance Notice. This will result in an estimated $13.8 billion increase in MA payments for CY 2024.

Medicare Part D: The changes from the Inflation Reduction Act to the Part D drug benefit will be implemented as described in the Advance Notice. The changes for CY 2024 include:

  • Elimination of cost sharing for covered Part D drugs for beneficiaries in the catastrophic phase of coverage.
  • Increased income limits from 135 percent of the federal poverty limit (FPL) to 150 percent of the FPL for the low-income subsidy program (LIS) under Part D for the full LIS benefit with a $0 deductible.
  • Continuation of the policy to not apply the deductible for any Part D covered insulin product. Also, in the initial coverage phase and the coverage gap phase, cost sharing must not exceed the applicable copayment amount, which for CY 2024 is $35 for a month’s supply of each covered insulin product.
  • Continuation of the policy not to apply the deductible to any adult vaccine recommended by the Advisory Committee on Immunization Practices (ACIP). Also, the statute requires these vaccines to be exempt from any co-insurance or other cost sharing, including cost sharing for vaccine administration and dispensing fees for such products, when administered in accordance with ACIP’s recommendation, for beneficiaries in the initial coverage and coverage gap phases.
  • Base beneficiary premium (BBP) growth will be held to no more than 6 percent by statute. The BBP for Part D in 2024 will be the lesser of the BBP for 2023 increased by 6 percent or the amount that would otherwise apply under the original methodology if the IRA were not enacted.

Star Ratings: Medicare Advantage star ratings for CY 2024 will include 30 measures with 12 included in the 2024 categorical adjustment index (CAI) values. By contrast, Part D star ratings for CY 2024 will include 12 measures with 5 of those measures included in the 2024 CAI values. The CAI for the 2024 Star Ratings is expected to be issued later in 2023. The CAI was introduced in 2017 as an interim analytical adjustment to address the average within-contract disparity in performance among beneficiaries who receive a low-income subsidy, are dual eligible, and/or are disabled.

The Final Rate Notice also includes three criteria for determining if Part C and D organizations are eligible for the “extreme and uncontrollable circumstances” adjustment to their Star Ratings. To be eligible, an organization must be in a 1) service area that is within the “emergency area” during the “emergency period,” 2) service area that is within a geographic area designated in a major disaster declaration under the Stafford Act and the Secretary exercised authority under the Act based on the same triggering events, and 3) a certain minimum percentage (25 or 60 percent) of beneficiaries must reside in the Federal Emergency Management Agency (FEMA) designated Individual Assistance area at the time of the extreme and uncontrollable circumstance. If an organization meets the criteria outlined and meets the 25 percent minimum, then they will receive the higher of their measure-level rating from the current and prior Star Ratings years for purposes of calculating the 2024 Star Ratings. For organizations meeting the 60 percent minimum and the other criteria, they are excluded from the measure-level cut point calculations for non-CAHPS measures, and the performance summary and variance thresholds.

Upcoming LinkedIn Live: Join HMA for our Future Frame Conversation on Policy Changes in Medicare Advantage and the Implications for Coding, Risk Adjustment, and Reimbursement.  Tuesday April 11, 2023, at 12 p.m. E.T. Click here to register.

If you have questions about the contents of CMS’s MA final notice and how it will affect MA plans, providers, and patients, contact Julie Faulhaber ([email protected]), Amy Bassano ([email protected]), or Andrea Maresca ([email protected]).

HMA News

Health Management Associates Acquires Crestline Advisors

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Jay Rosen, founder, president, and co-chairman of Health Management Associates (HMA), today announced the firm’s acquisition of Crestline Advisors, an Arizona based healthcare consulting firm.

Founded in 2013, Crestline Advisors supports health plans, provider organizations, and state agencies with an array of services designed to help them navigate the changing healthcare landscape. The company’s team of independent consultants has an extensive track record of developing successful RFP responses, provider networks, and business development strategies to fuel client success.

“Crestline Advisors brings an impressive mix of expertise and relentless client focus – that delivers results – to HMA,” Rosen said. “Their ability to consistently develop winning proposal responses for Medicaid managed care organizations (MCO) complements our extensive MCO supports as we continue to expand the ways in which we serve our clients.”

In addition to Crestline’s proposal response development and MCO network management and operations support services, the company also assists clients with regulatory and contract compliance, accreditation, and strategic planning for business development.

“Crestline has demonstrated a commitment to supporting health plans, providers, and states to improve healthcare for Medicaid beneficiaries,” said Crestline CEO Susan Dess. “We firmly believe that as part of the HMA family of companies we will bring even more success to our clients and drive continued growth and development in Medicaid healthcare delivery.”

Dess and Tim Mechlinski will continue to lead Crestline Advisors, an HMA Company, as managing directors. Terms of the transaction were not disclosed.

About HMA

Founded in 1985, HMA is an independent, national research and consulting firm specializing in publicly funded healthcare and human services policy, programs, financing, and evaluation. Clients include government, public and private providers, health systems, health plans, community-based organizations, institutional investors, foundations, and associations. With offices in more than 20 locations across the country and over 500 multidisciplinary consultants coast to coast, HMA’s expertise, services, and team are always within client reach. Learn more about HMA at, or on LinkedIn and Twitter.

About Crestline Advisors

Established in 2013, Crestline Advisors, LLC is a consulting company designed to support the needs of health plans, provider organizations, and state agencies. Crestline specializes in helping large and small organizations operate successfully and grow despite the constant operational, financial, and political challenges they face. Crestline uses its current understanding of industry drivers to strategize with our clients so they can respond timely and effectively to small, large, or enormous market-place changes. Learn more about Crestline Advisors at


Behavioral health Section 1115 demonstration waivers and waiver extensions

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Health Management Associates (HMA) is a national leader in supporting states with the design, development, negotiation and implementation of Section 1115 demonstration waivers and waiver
extensions. HMA has assisted more than 20 Medicaid departments directly with their state plan amendments, waivers, and other demonstration projects – and most recently supported Alaska, Colorado, Delaware, Indiana, Missouri, and Oklahoma.

HMA’s behavioral health team is currently working with multiple Medicaid agencies on the development of substance use disorder (SUD), serious mental illness (SMI), and serious emotional disturbance (SED) specific 1115 waivers.

We pair our behavioral health and Medicaid subject matter experts to support states with:

  • Developing and applying for SMI/SED and SUD Section 1115 demonstration waivers.
  • Implementing SMI Section 1115 demonstration waivers.
  • Providing an assessment of the requirements under the Section 1115 demonstration waiver and Medicaid managed care “in lieu of” authorities, including requirements for average length of stay,
    provider oversight, and monitoring, as well as other considerations.
  • Reviewing managed care contract requirements and providing applicable Medicaid managed care contract language for states that are utilizing “in lieu of” authority to provide reimbursement for inpatient or residential stays in IMDs.
  • Technical assistance with developing administrative infrastructure to monitor utilization, including
    adherence to length of stay requirements under the waiver and “in lieu of” options. CMS’ SMI Section 1115 demonstration waiver guidance prohibits states from receiving Federal Financial Participation (FFP) for any IMD stays that exceed 60 days. In cases where states do not meet this metric, CMS can reduce this maximum length of stay (LOS) to 45 days or less. HMA understands it is important for states to have utilization management (UM) strategies in place to identify these instances and minimize the state’s financial risk, and can therefore provide examples of state UM strategies, as well as incentives to manage inpatient and residential LOS while maintaining access to medically necessary services.
  • Supporting design of data capture and reporting functions for meeting wavier requirements.
  • Serving as the independent evaluator for approved SUD and/or SMI/SED 1115 waiver demonstrations.

Contact Our Experts:

Stephanie Baume

Stephanie Baume


Stephanie Baume is a Medicaid expert with over 15 years of experience leading states in developing and implementing new health … Read more
Gina Eckart

Gina R. Eckart

Managing Director, Behavioral Health

Gina R. Eckart is a licensed mental health counselor with 20 years of experience in public behavioral health. Prior to … Read more
Debbie Saxe

Debbie Saxe


Debbie Saxe is a seasoned healthcare leader with a vast amount of state policy, research, and operations experience across a … Read more