On June 12, the Centers for Medicare and Medicaid Services (CMS) issued an Informational Bulletin reiterating concerns raised in a report issued by the Office of Inspector General (OIG), which found wide variation in appeal and grievance rates within and across state Medicaid programs and highlighted significant gaps in state data collection and oversight.

The bulletin responds to these concerns and reminds states of obligations to ensure access to Medicaid covered services for beneficiaries served by Medicaid Managed Care Organizations by collecting and reviewing data and information on two priorities: 1) mental health and substance use disorder parity and 2) prior authorization, denial, and appeals rates.

With these concerns in mind, CMS reminds states of additional obligations from the Final Interoperability and Patient Access Rule released in February of this year (LeadingAge analysis of the rule is available here). The rule adds requirements of states to collect and report data to CMS and includes timelines for necessary managed care contract amendments.  While the rule does not have a direct effect on providers, CMS attention to prior authorization as a barrier to services aligns with LeadingAge concerns with challenging and obscure prior authorization processes. The full bulletin can be accessed here.