In a recent Home Health Line feature titled "State budget cuts and electronic visit verification among 2024 challenges," Kyle Simon, HCAF's Senior Director of Policy, Advocacy & Communications, shared insights into the complex landscape ahead for Medicaid providers.

The article, published in the January 22 issue, explores the current and future challenges resulting from the gradual reduction of federal matching funds and eased regulations established under the Families First Coronavirus Relief Act (FFCRA) and the American Rescue Plan Act (ARPA). These measures, pivotal in boosting the Federal Medical Assistance Percentage (FMAP) rate for Medicaid-participating agencies during the pandemic, face expiration or have already expired. Simon emphasized the potential consequences, including reduced reimbursement rates, and the cessation of one-time funding for enhancing access to home- and community-based services (HCBS), which effectively ended for Florida providers at the end of 2023, impacting agencies' operational and financial sustainability.

A crucial focal point in the article is the looming challenge of the proposed rule, Medicaid Program; Ensuring Access to Medicaid Services, which proposes that 80% of Medicaid payments for essential services be directed to workers. Simon, expressing significant concern, particularly for states like Florida with low reimbursement rates, highlighted the potential shortfall in covering overhead and administrative costs with the remaining 20%. HCAF submitted comments on the proposal on behalf of Medicaid providers last summer, stressing that the rule may hinder access to care, with providers operating in a deficit or even withdrawing from the program. The Centers for Medicare & Medicaid Services (CMS) sent the proposed rule to the Office of Management and Budget (OMB) last week, which is the final step in the rulemaking process. A final rule is anticipated in the spring.

The 21st Century Cures Act's Electronic Visit Verification (EVV) requirements for Medicaid home health services add another layer of complexity, with an effective date of January 1, 2024. Despite Florida providers having a head start due to the state's pre-pandemic implementation, Simon acknowledged the challenges associated with nationwide compliance.

Simon urged Medicaid providers to proactively tackle the impending challenges of 2024. He emphasized the importance of staying well-informed about proposed policy changes, particularly related to Medicaid reimbursement, and engaging with state legislatures to safeguard HCBS. He underscored the critical role of associations like HCAF, providing a unified voice in advocacy efforts and ensuring that provider concerns are integral to policymaking discussions.