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CMS Breathes New Life into Medicaid HCBS Investment Opportunities

On June 3, 2022, the Centers for Medicare & Medicaid Services (CMS) notified states that they will have an additional year, until March 31, 2025, to use funding from the American Rescue Plan Act (ARPA) to strengthen their Medicaid home and community-based services (HCBS). CMS’ update extends important flexibility to ensure state Medicaid programs and stakeholders, including beneficiaries, realize maximum benefit from federal investments in expanding and enhancing HCBS services.

For over a decade, the Medicaid program has been leading transformations of state long-term services and supports systems (LTSS), including physical and behavioral health services and health-related social needs. These efforts primarily focus on broadening eligibility, making more significant Medicaid investments in HCBS, and improving beneficiaries’ access to HCBS programs. The COVID-19 pandemic heightened attention to beneficiaries’ disparate experiences with accessing HCBS and exacerbated pre-COVID challenges faced by the LTSS workforce.

Section 9817 of ARPA provides an increase for Medicaid-funded HCBS by offering states the option to claim an additional 10 percentage point increase in federal match (FMAP) for the one-year period from April 1, 2021, to March 31, 2022. To receive the higher federal funding, states cannot make changes to the amount, duration, and scope of covered HCBS; they cannot reduce HCBS provider payment rates; and they cannot make eligibility standards for HCBS programs or services stricter until all additional funds are expended. CMS also requires states to submit a spending plan and narrative that describes planned enhancement activities.

Notably, a state must reinvest the higher federal funding in Medicaid HCBS while maintaining the spending levels they had in place on April 1, 2021. According to CMS’s new guidance, states can now use the funds until March 31, 2025, rather than March 31, 2024, under the previous guidance.

Actions Stakeholders Can Take to Maximize the Extra Time

The updated spending deadline is grounded in a better understanding of the level of effort and time necessary for states to identify, build consensus, and implement specific actions to include in a state’s HCBS spending plan. HMA works with states, providers, health plans, and other stakeholders, including consumers, who will benefit from the additional time to make investments. Our work includes supporting states as they align the multitude of needs and priorities with the available funds and supporting robust stakeholder engagement efforts to inform the plans.

The following are some of the most impactful “next steps” that states and stakeholders can pursue to best utilize the additional time to reinvest in Medicaid HCBS programs:

  • States can communicate with stakeholders, including health plans, providers, community organizations, consumers, and others, to share how the extension impacts the state’s spending plan.
  • States and stakeholders can renew their engagement to consider potential changes to the spending plan activities, timelines, or both. Stakeholders may have additional opportunities to offer input to refine further and prioritize the design and delivery of augmented or new services, systems, and related initiatives.
  • State Medicaid, aging, and various other programs and providers have more time to strengthen their collaboration to meet the needs of individuals of all ages who are living with disabilities.
  • States, vendors, health plans, and providers can evaluate through evidence, analysis and stakeholder feedback, if the projects they are pursuing are effective and/or should be modified. For example, it may be beneficial to provide more flexibility in the deadlines for case management and referral systems builds and implementation of the training for workers on these new systems.
  • States and their stakeholder partners can refocus on workforce issues, including examining eligible provider types and scopes, evaluating provider network issues, considering the role of virtual services, conducting provider and managed care rate setting studies, and other changes to support the HCBS direct care workforce.
  • States can develop reasonable timeframes to strengthen existing efforts or pursue new initiatives to develop and implement managed long-term services and supports for certain groups of Medicaid beneficiaries.

Looking ahead, states and all stakeholders need to assess the impact of these investments. ARPA funds are a significant investment in strengthening Medicaid LTSS programs, but these transformative efforts require sustained commitment. There is continued uncertainty around additional federal Medicaid funding over the long term that are necessary to address ongoing needs and make further progress towards high-quality, accessible HCBS services. Understanding the extent to which the funds are achieving the desired structural transformations and the impact on Medicaid beneficiaries can guide future areas of federal and state focus and investments.

For more information please contact HMA consultants Kevin Hancock, Principal, Andre Marescaa, Principal, and Aaron Tripp, Principal.

Related posts:

HMA Roundup


Dentists Collect Signatures for Ballot Initiative on Increasing Medicaid Reimbursements. 9 News reported on June 11, 2022, that Colorado dentists have begun collecting signatures in support of a ballot initiative that would increase Medicaid dental reimbursement rates from 45 percent of the procedure cost to 73 percent. The initiative needs 125,000 signatures by registered voters to earn a spot on the November ballot. Read More


Delaware Delays Medicaid Managed Care Contract Awards to July. Health Payer Specialist reported on June 8, 2022, that Delaware has delayed awards for its Medicaid managed care procurement until July 1. Incumbent plans are AmeriHealth Caritas Delaware and Highmark Health Options. Both incumbents submitted proposals, as did Centene and UPMC Health Plan. According to the request for proposals released in December 2021, Delaware intends to award contracts to two or three bidders. Contracts will be effective January 1, 2023, and run for five years with three optional one-year extensions. Read More


Florida Names Bidders In Modular MMIS Procurement. Florida Politics reported on June 8, 2022, that the Florida Agency for Health Care Administration (AHCA) received five responses to an invitation to negotiate for the provider service component of the state’s modular Medicaid management information system (MMIS). Bidders included Gainwell Technologies, Optum, HHS Tech Group, FEI Systems, and Digital Harbor. AHCA also received bids for the unified operations center module from Conduent State Healthcare, Gainwell Technologies, Deloitte, Automated Health Systems TTEC, Cognosante, and Maximus. Contracts are set to be awarded on June 30. The modular MMIS initiative is called Florida Health Care Connections. Read More


Louisiana Names Additional Medicaid Managed Care Contract Winner. The Louisiana Department of Health announced on June 9, 2022, its intent to award a Medicaid managed care organization contract to incumbent UnitedHealthcare in addition to the five other health plans named in February 2022. Contract implementation has been delayed six months to January 2023, and the contracts will run for three years with an option to extend up to two more years. The other contract winners are AmeriHealth Caritas, Anthem/Healthy Blue, Centene/Louisiana Healthcare Connections, CVS/Aetna Better Health, and Humana. Read More


Governor Creates Cabinet on Aging to Address Needs of Older Residents. The Associated Press reported on June 13, 2022, that Maine Governor Janet Mills created a Cabinet on Aging to ensure older residents have access to health care and other supports as they age. Maine has the oldest median age in the country, with tens of thousands of residents planning on retiring. Cabinet members include the commissioners of several state departments, including the Maine Department of Health and Human Services. The cabinet will meet at least four times per year, starting in July. Read More


Maryland Releases Draft Medicaid 1115 Waiver Amendment to Cover Ambulance Transport, Dental Services. State of Reform reported on June 10, 2022, that the Maryland Department of Health (MDH) released a draft 1115 waiver amendment to extend Medicaid coverage to the Alternative Destination Pilot (ADP) and Adult Dental Pilot in accordance with a recently passed state law. The ADP allows ambulance providers to transport patients to destinations other than emergency departments, if appropriate. The Adult Dental Pilot program provides dental coverage to dual eligibles aged 21 to 64. Recently enacted legislation would remove the $800 cost cap and expand coverage to all Medicaid-eligible adults, effective January 1, 2023. MDH is accepting public comments through June 25, 2022. Read More

Maryland Announces $81 Million in Federal EMS Funding. State of Reform reported on June 14, 2022, that the Maryland Department of Health announced $81 million in federal funding toward the cost of emergency medical services (EMS) for Medicaid participants between October 1, 2020, through June 30, 2021. The funding, from the Centers for Medicare & Medicaid Services, will be distributed through the state’s Emergency Service Transporter Supplemental Payment Program to Jurisdictional Emergency Medical Services Operational Programs. Read More


Michigan Dentists Call for Increase in Medicaid Reimbursement Rates. Michigan Radio reported on June 15, 2022, that Michigan dentists are urging the state to increase Medicaid reimbursement rates for dentists to improve access to care for beneficiaries. Dentists argue that low fees are limiting access to dental care for Medicaid beneficiaries in the state. Read More


Montana Does Not Consistently Verify Eligibility for Medicaid, CHIP, Audit Finds. The Great Falls Tribune/The Daily Montanan reported on June 10, 2022, that the Montana Department of Public Health and Human Services has not consistently verified eligibility for Medicaid and the Children’s Health Insurance Program (CHIP), according to an audit from the Legislative Audit Division for fiscals 2020 and 2021. The audit also found that the state does not have a system in place to stop individuals convicted of Medicaid fraud from receiving benefits, and it may have overpaid some foster care subcontractors tens of thousands of dollars. Read More

New Mexico

New Mexico Settles with Medicaid Plan Over PBM Fraud Allegations. Modern Healthcare reported on June 14, 2022, that Centene will pay New Mexico $13.7 million in a settlement over allegations that its former pharmacy benefit management operation (PBM) overcharged the state’s Medicaid program for prescription drugs. Other states settling with Centene over PBM-related allegations are Arkansas, Illinois, Kansas, Mississippi, and Ohio. Read More

North Carolina

North Carolina Foundation to Study Whether State Should Transition Medicaid Oral Health to Managed Care. North Carolina Health News reported on June 14, 2022, that the North Carolina Oral Health Collaborative will study and potentially make recommendations on whether the state should transition Medicaid oral health services from fee-for-service to managed care. The goal is to have recommendations completed before the state begins its next Medicaid managed care procurement process in 2024. Read More

Senate Committee Considers Bill to Carve-Out Foster Care Services from Managed Care. The Winston-Salem Journal reported on June 12, 2022, that the North Carolina Senate Health Care committee is considering a bill (House Bill 144) that would carve-out foster care services from Medicaid behavioral managed care plans. Instead, the Department of Health and Human Services (DHHS) would seek proposals from prepaid health plans operated by health insurers who already have contracts with DHHS to procure a single statewide children and families specialty plan. The bill advanced out of the Senate Rules and Operations committee and was placed on the floor agenda, but it was then withdrawn and added to the Health Care committee agenda. The bill passed in the state House in May 2021. If the bill passes, the plan would launch by December 1, 2023. Read More

Senate Passes Medicaid Expansion Bill. Insurance News Net reported on June 9, 2022, that the North Carolina Senate passed a bill (HB 149) to expand Medicaid to approximately 600,000 adults. The bill includes a provision for work requirements, which has been struck down in other states. The bill also includes changes to certificate of need statutes and increased telehealth options, allowing advanced practice nurses to practice without physician supervision. The House will most likely not take up the bill during the current session. Read More

Hospitals Raise Concerns Over Certificate of Need Changes in Medicaid Expansion Bill. North Carolina Public Radio reported on June 3, 2022, that the North Carolina Healthcare Association (NCHA) does not support modifications to certificate of need laws outlined in a Medicaid expansion bill passed by the state Senate, according to an NCHA statement. However, NCHA supports Medicaid expansion to reduce the amount of charity care provided by member hospitals. Read More

South Dakota

Secretary of State Validates Second Medicaid Expansion Ballot Measure. The Yankton Daily Press & Dakotan reported on June 10, 2022, that a second ballot measure to expand Medicaid in South Dakota was validated by Secretary of State Steve Barnett. The measure, Initiated Measure 28, will appear on the November ballot alongside Constitutional Amendment D, which also seeks to expand Medicaid. Read More


Texas Health Plan Did Not Meet Fraud, Abuse Detection Requirements, State Report Says. The Texas Health and Human Services Commission Office of the Inspector General (OIG) reported on June 14, 2022, that Medicaid plan Community First Health Plans did not meet state requirements related to preventing, detecting, and investigating fraud, waste, and abuse between September 1, 2019, and August 31, 2020, according to an OIG audit. Community First plans to implement corrective actions outlined in the audit by June 2022. Read More

Texas Seeks to Extend Medicaid Postpartum Coverage to Six Months. The Centers for Medicare & Medicaid Services announced on June 10, 2022, that the Texas Health and Human Services Commission submitted a Section 1115 waiver amendment request to extend Medicaid postpartum coverage for eligible women to six months, a four month increase from current coverage. If approved, the extension will be effective September 22, 2022. Public comments will be accepted through July 10, 2022. Read More

West Virginia

West Virginia Submits SUD Continuum of Care 1115 Waiver Renewal for Federal Approval. The Centers for Medicare & Medicaid Services announced on June 10, 2022, that West Virginia is seeking federal approval to renew its “creating a continuum of care” Section 1115 waiver for Medicaid enrollees with substance use disorder (SUD) for another five years. The renewal would continue current programs, reimburse short-term inpatient treatment services, expand services for high-risk individuals, and implement recovery housing options. Comments will be accepted until July 10, 2022. Read More


Legislators Consider Extending Medicaid Postpartum Coverage to One Year. WyoFile reported on June 9, 2022, that the Wyoming Joint Health, Labor, and Social Services Committee is considering extending postpartum Medicaid coverage for pregnant women from 60 days to one year through a state plan amendment. The Committee will consider outcomes and a sample bill at its next meeting in August. Read More


CMS Variation of Reimbursement Rates for 340B Hospitals is Unlawful, Supreme Court Rules. Modern Healthcare reported on June 15, 2022, that the Centers for Medicare & Medicaid Services (CMS) does not have authority to change 340B reimbursement rates without surveying hospital acquisition costs, according to a unanimous ruling by the U.S. Supreme Court. The ruling concludes that CMS’ variation of reimbursement rates for 340B hospitals in 2018 and 2019 were unlawful. Read More

MACPAC Recommends New System for Monitoring Access to Medicaid Care Across States, Delivery Systems. The Medicaid and CHIP Payment and Access Commission (MACPAC) released on June 15, 2022, its report to Congress on Medicaid and Children’s Health Insurance Program for June 2022, which recommends creating a new system for monitoring access to Medicaid care across states and delivery systems. The report also focuses on transparency of Medicaid managed care directed payments, improved access to vaccines, integrated care standards for dual eligibles, advancing health equity in Medicaid, and how the adoption of information technology among behavioral health providers can better integrate care for Medicaid beneficiaries. Read More

AMA Looks to Block Expansion of Non-Physician Scope of Practice. Modern Healthcare reported on June 14, 2022, that the American Medical Association (AMA) will help craft state legislation that opposes expanding the scope of practice for non-physicians and reversing laws that have already done so. AMA will also conduct research on cost and quality of care under nurse practitioners, physician assistants, and other advanced practice practitioners without a doctor’s supervision. Read More

Medicaid Managed Care Enrollment Approaches 68 Million in 2020, CMS Reports. The Centers for Medicare & Medicaid Services (CMS) announced on June 13, 2022, that 67.8 million individuals were enrolled in some form of Medicaid managed care as of July 1, 2020. Total Medicaid enrollment exceeded 80 million in 2020. California had the highest total Medicaid enrollment of any state at 13 million. Read More

U.S. Senators Include Funds for Expanded Mental Health Resources in Bipartisan Agreement on Guns. NPR reported on June 12, 2022, that a bipartisan group of U.S. Senators developed a framework for gun-related legislation that would include funding for expanded mental health resources for schools and a national expansion of community behavioral health centers. The proposal would also provide funds for “red flag” laws, school safety, and expanded background checks. The Senate is not expected to vote soon on the legislation, but Senators are optimistic that it will eventually pass with at least 60 votes. Read More

Biden Administration Considers Requirement for Nursing Homes to Spend Majority of Medicaid Dollars on Direct Care. Kaiser Health News reported on June 10, 2022, that the Biden administration is considering a proposal to require nursing homes to spend most of their Medicaid payments on direct care for residents and limit the amount going to operations, maintenance, capital improvements, or profits. Medicaid covers 62 percent of long-term care nursing home residents. Read More

MACPAC Encourages CMS to Use Health Equity Lens For Minimum Nursing Home Staffing Standards. The Medicaid and CHIP Payment and Access Commission (MACPAC) issued on June 10, 2022, a letter to Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure that encourages CMS to apply a health equity lens when developing new minimum staffing standards for nursing facilities. This is based on a recently conducted review of pre-pandemic staffing data, which found that nursing facilities that serve a higher share of Medicaid-covered residents were much more likely to have lower staffing rates and more racial and ethnic minorities compared to other facilities. The letter was in response to a request for information from CMS on revising requirements for long-term care facilities to establish mandatory minimum staffing levels. Read More

U.S. Representative Introduces Bill to Implement Medicaid Work Requirements. WIBW reported on June 9, 2022, that U.S. Representative Jake LaTurner (R-KS) introduced a bill that would require all able-bodied adults to work or volunteer for no less than 20 hours per week to remain eligible for Medicaid. Read More

CMS Issues First Hospital Pricing Regulation Penalties. Fierce Healthcare reported on June 9, 2022, that the Centers for Medicare & Medicaid Services (CMS) issued civil penalties to two Northside Hospital facilities in Georgia for violating hospital price transparency regulations. Northside Hospital Atlanta was penalized $880,000, and Northside Hospital Cherokee was penalized $214,000. The regulations, which require hospitals to publish accessible pricing information online, went into effect on January 1, 2021. Read More

Industry News

Gainwell Is Eligible to Bid on State Medicaid Third Party Liability Contracts Under NASPO ValuePoint. Gainwell Technologies announced on June 14, 2022, that its subsidiary HMS is eligible to provide third party liability (TPL) services to state Medicaid agencies through the National Association of State Procurement Officials (NASPO) ValuePoint TPL Services contract. Read More

Ohio Community Organizations Receive $4.6 Million from Humana. Humana announced on June 15, 2022, that its Healthy Horizons Medicaid operation invested $4.6 million in Ohio community organizations to address social determinants of health. Funds went to The Foodbank, Greater Cleveland Food Bank, Mid-Ohio Food Collective, Volunteers of America Ohio & Indiana, CHN Housing Partners, March of Dimes, Ohio Academy of Family Physicians, and Ohio University. Read More

Sverica Capital Management Invests in SG Homecare. Sverica Capital Management announced on June 14, 2022, an investment in SG Homecare, a California-based provider of medical equipment, prosthetics, orthotics, and supplies to home-based patients. SG Homecare chief executive Thomas Rowley will continue to lead the company. Read More

FTC Requests Information About UnitedHealth’s Proposed Acquisition of LHC Group. Modern Healthcare reported on June 10, 2022, that the Federal Trade Commission has requested additional information related to UnitedHealth Group’s proposed $5.4 billion acquisition of home healthcare provider LHC Group. The request adds 30 days to the close date, which was expected to be in the second half of 2022. Read More

Humana’s Onehome to Serve Company’s Medicare Members in Virginia. Humana announced on June 9, 2022, that its Onehome subsidiary will be coordinating home care services for Humana Medicare Advantage plan members in Virginia. Humana acquired onehome in 2021. Read More

RFP Calendar

HMA News & Events

Trends in Behavioral Health to Be Highlighted at HMA Conference in Chicago, October 10-11

Top executives from Medicaid managed care plans, state Medicaid departments, and provider organizations will seek to answer your most pressing questions and concerns about the future of behavioral health during HMA’s fifth annual conference, October 10-11, 2022, at the Fairmont Chicago, Millennium Park.

To view a complete agenda and to register visit https://conference.healthmanagement.com/.

Speakers participating in the behavioral health session are:

Cristen Bates, Interim Medicaid Director, CO Department of Healthcare Policy & Financing
Michael Brodsky, MD, Medical Director for Behavioral Health and Social Services, L.A. Care Health Plan

Mark Sasvary, Chief Clinical Officer, CBHS, IPA, LLC
Courtnay Thompson, Market President, Select Health of SC, an AmeriHealth Caritas Company

Speakers will address the challenges and opportunities facing behavioral health organizations and patients, including the impact of staffing shortages, rising needs of patients seeking behavioral care, quality and accountability of value-based payment models, restructuring by states of behavioral health programs, and emergence of Certified Community Behavioral Health Clinics (CCBHCs).

The overall theme of this year’s conference is How Medicaid, Medicare, and Other Publicly Sponsored Programs Are Shaping the Future of Healthcare in a Time of Crisis. HMA will also host a pre-conference workshop on Sunday, October 9, on important trends and developments in value-based care.

Conference keynote speakers include:

Drew Altman, President and CEO, Kaiser Family Foundation
John Barger, National VP, Dual Eligible and Medicaid Programs, Humana, Inc.
Jacey Cooper, Medicaid Director, Chief Deputy Director, California Department of Health Care Services
Aimee Dailey, President, Medicaid, Anthem, Inc.
Rebecca Engelman, EVP, Medicaid Markets, AmeriHealth Caritas
Brent Layton, President, COO, Centene Corporation
Allison Matters Taylor, Medicaid Director, Indiana
Kelly Munson, President, Aetna Medicaid
Dave Richard, Deputy Secretary, North Carolina Medicaid
Jami Snyder, Director, Arizona Health Care Cost Containment System
Timothy Spilker, CEO, UnitedHealthcare Community & State

Conference featured speakers include:

Michael Brodsky, MD, Medical Director, Behavioral Health and Social Services, L.A. Care Health Plan
Cindy Cota, Director of Managed Medicaid Growth and Innovation, Volunteers of America
Daniel Elliott, MD, Medical Director, Christiana Care Quality Partners, eBrightHealth ACO, ChristianaCare Health System
Rebecca Engelman, EVP, Medicaid Markets, AmeriHealth Caritas
Martin Lupinetti, President, CEO, HealthShare Exchange (HSX)
Andrew Martin, National Director of Business Development (Housing+Health), UnitedHealth Group
Taylor Nichols, Director of Social Services, Los Angeles Christian Health Centers
Thomas Rim, VP, Product Development, AmeriHealth Caritas
Todd Rogow, President, CEO, Healthix
Debra Sanchez-Torres, Senior Advisor, Centers for Disease Control and Prevention
Mark Sasvary, Chief Clinical Officer, CBHS, IPA, LLC
Jim Sinkoff, Deputy Executive Officer, CFO, SunRiver Health
Tim Skeen, Senior Corporate VP, CIO, Sentara Healthcare
Courtnay Thompson, Market President, Select Health of SC, an AmeriHealth Caritas Company
Joshua Traylor, Senior Director, Health Care Transformation Task Force
Amanda Van Vleet, Associate Director, Innovation, NC Medicaid Strategy Office, North Carolina Department of Health & Human Services
James Whittenburg, CEO, TenderHeart Health Outcomes
Shannon Wilson, VP, Population Health & Health Equity, Priority Health; Executive Director, Total Health Care Foundation
Mary Zavala, Director, Enhanced Care Management, L.A. Care Health Plan

HMA’s last national conference brought together 500 executives from health plans, providers, state and federal government, community-based organizations and others serving Medicaid, Medicare, and other vulnerable populations. Sponsorships and group discounts are available. For additional information, contact Carl Mercurio.



Medicaid Data   

  • Arizona Medicaid Managed Care Enrollment is Up 1.9%, Mar-22 Data
  • Maryland Medicaid Managed Care Enrollment Is Up 1.5%, Mar-22 Data
  • Nebraska Medicaid Managed Care Enrollment Is Up 3.2%, Mar-22 Data
  • New York CHIP Managed Care Enrollment is Down 3%, 2021 Data
  • New York Medicaid Managed Care Enrollment is Up 6%, 2021 Data
  • Tennessee Medicaid Managed Care Enrollment is Up 2%, Apr-22 Data

Public Documents:                                                                                                         

Medicaid RFPs, RFIs, and Contracts:

  • Alabama Medicaid Community Waiver Program RFP, Jun-22
  • Arizona PBM for the AIDS Drug Assistance Program RFP, Jun-22
  • Missouri Medicaid DSH Payment Audit Services RFP, Jun-22
  • Wyoming Dental Benefits Manager RFP, Jun-22

Medicaid Program Reports, Data and Updates:

  • District of Columbia Medicaid MCO External Quality Review Annual Technical Reports, 2014-21
  • Florida Annual External Quality Review Reports, 2012-21
  • Idaho DHW Annual Reports, 2019-21
  • MACPAC Reports to Congress on Medicaid and CHIP, 2017-22
  • Massachusetts MassHealth MCO EQR Technical Reports, 2017-21
  • Montana Department of Public Health and Human Services Financial Compliance Audit, FY 2019-21
  • Ohio Medicaid External Quality Review Reports, 2017-21
  • Vermont Blueprint for Health Annual Reports, 2015-21
  • Wyoming Medicaid Care Management Entity EQR Report, SFY 2021

A subscription to HMA Information Services puts a world of Medicaid information at your fingertips, dramatically simplifying market research for strategic planning in healthcare services. An HMAIS subscription includes:

  • State-by-state overviews and analysis of latest data for enrollment, market share, financial performance, utilization metrics and RFPs
  • Downloadable ready-to-use charts and graphs
  • Excel data packages
  • RFP calendar

If you’re interested in becoming an HMAIS subscriber, contact Carl Mercurio.

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