Wildfire: Igniting Community Action to End Poverty in Arizona Issues Public Comment on Centers for Medicare & Medicaid Services Proposed Rule

WASHINGTON, Feb. 10 -- Cynthia Zwick, executive director of Wildfire: Igniting Community Action to End Poverty in Arizona, Phoenix, has issued a public comment on the Centers for Medicare and Medicaid Services' proposed rule entitled "Medicaid Program: Medicaid Fiscal Accountability Regulation". The comment was written on Jan. 31, 2020, and posted on Feb. 6, 2020:

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I am writing on behalf of Wildfire: Igniting Community Action To End Poverty in Arizona. This letter is in response to the Centers for Medicare Medicaid Services (hereby referred to as CMS) request for comments regarding "Medicaid Program; Medicaid Fiscal Accountability Regulation," published to the Federal Register on November 18, 2019. We appreciate the opportunity to provide comment on the proposed rule change.

Wildfire is a statewide anti-poverty organization and Arizona's State Community Action Association. For over half a century, Wildfire has worked to alleviate the impact of poverty in Arizona. We advocate for fair practices, collaborate on policy issues, and support community action programs and agencies. Beyond easing the effects of poverty, we hope to ignite lasting change, to "stop poverty before it starts."

Wildfire is committed to creating an Arizona where all may thrive by connecting families to services that help them make it through another day. This includes ArizonaSelfHelp.org, a free and easy way for families to get help from 40 different health and human services program, including our state Medicaid programs. Meaningful access to quality affordable health care is a human right. We believe in universal coverage for all community members, which includes affordable prescription drugs, reductions in geographic and categorical barriers to access, and provision of mental health services. All members of our community deserve a health care system that allows them to live healthy lives while pursing their goals.

The rule, if finalized, would do the opposite. It could potentially have a large, harmful effect on Arizona's Medicaid budget, health care providers in our state, and access to care for the 1,880,915 low-income Medicaid beneficiaries in Arizona. In Arizona, 39% of children receive health coverage through Medicaid or CHIP, and this rule threatens to disrupt that coverage. We believe CMS should not finalize any of the new standards for approval and substantive rule changes for state financing and supplemental payments. These changes would put state Medicaid programs at risk, without adequate research into the impact on state Medicaid programs and Medicaid participants.

The proposed rule would inject significant uncertainty about many existing financing and supplemental payments and could result in states scaling back Medicaid services and/or eligibility. The rule would add new vague or ill-defined standards of review for not only new state financing mechanisms and supplemental payments, but also existing arrangements that have already received federal approval and have been in place for many years. Arizona's Medicaid program alone could face a two billion dollar funding deficit if this rule were to go into effect in its current form.

The proposed rule would effectively bar intergovernmental transfers comprised of private insurance revenues and charitable donations, and would set a new upper limit on supplemental payments to physicians and other health practitioners equal to 50 percent of base payments (and 75 percent for services in a Health Professional Shortage Area).

Currently, such supplemental payments may not exceed a higher limit based on the Average Commercial Rate. Both rural and urban areas in Arizona have been designated Health Professional Shortage Areas. This could disincentivize providers from working in remote and/or underserved areas and have a devastating impact on access to care.

Nearly every state, including Arizona, relies on provider taxes to help finance their share of Medicaid costs. For example, in state fiscal year 2019, Arizona's Medicaid system was partially funded by assessments charged on hospitals. The proposed rule would inhibit states' flexibility to fund their Medicaid programs through such assessments and could also prohibit or limit existing supplemental payments our state is making to health care providers. In Arizona's vast rural areas, and in its underserved urban centers, these payments are critical to incentivizing provider participation in the Medicaid program.

The fiscal and public health impacts of this rule have not been properly examined and are not well understood. These changes would have a disproportionately negative impact on low-income communities. We respectfully implore CMS to not finalize any of the standards proposed in the rule without a thorough investigation of its impact on states and on Medicaid participants.

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The proposed rule can be viewed at: https://www.regulations.gov/document?D=CMS-2019-0169-0001

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