On Nov. 28, 2019, the Centers for Medicare & Medicaid Services (CMS) issued a proposed rule entitled “Medicaid Fiscal Accountability Regulation” (MFAR). MFAR is a sweeping proposed rule that focuses on multiple aspects of the fiscal relationship between the federal government and state Medicaid agencies. The most significant changes focus on: supplemental payments under a state plan or demonstration authority (often through a directed payment program (DPP)); state funding sources (intergovernmental transfers, certified public expenditures (CPEs) and provider taxes and donations in particular); disproportionate share payments (DSH); and upper payment limits (UPLs).
The proposed rule would impose significant new reporting requirements on all supplemental payments going forward, as it relates to both existing programs and supplemental payment programs established in the future.
Yelena Barzilla, LL.B., LL.M., CHC
Ryan M. Sims, JD