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MACPAC Releases its March 2025 Report

The Situation Report | March 24, 2025

The Medicaid and CHIP Payment and Access Commission (MACPAC) recently released its semi-annual repor, including three chapters and multiple recommendations. The following is a listing of each chapter and the associated recommendations with an emphasis on applicability to home care services:  

Chapter 1: External Quality Review in Medicaid Managed Care 

Over 70% of beneficiaries nationally are enrolled in managed care for at least a portion of their Medicaid services, including a growing number of states that include home and community-based services as part of the managed care offerings. Every state utilizing managed care must contract with an independent organization to perform an annual external quality review (EQR) of each plan participating in their program. The EQR is a core component of Medicaid managed care plan oversight. EQR Organizations must perform and report on validation of performance improvement projects and performance measures; plan compliance with enrollee rights, disenrollment limitations, and emergency and post-stabilization service requirements; and network adequacy requirements. States can also include optional activities regarding validation of encounter data, validating consumer and provider surveys, calculating performance measures, and calculating performance measures, among other activities. 

MACPAC Recommendations 

  • Require the EQR annual technical report include outcomes data and results from quantitative assessments collected and reviewed; 
  • Update EQR protocols to: 
  • Reduce areas of duplication with other federal quality and oversight reporting requirements; 
  • Create a more standardized structure in the annual technical report that summarizes EQR activities, results, and actions taken by state Medicaid agencies; and 
  • Identify key takeaways on plan performance. 
  • Require states to publish the annual EQR technical reports in a 508-compliant format and for CMS to publicly post all state EQR reports in a central repository on the CMS website. 

Chapter 2: Timely Access to Home and Community Based Services (HCBS) 

In this chapter, MACPAC outlines multiple issues that lead to delays in eligible individuals receiving HCBS.  MACPAC includes one recommendation in this chapter: 

  • Direct the U.S Centers for Medicare and Medicaid Services (CMS) to issue guidance on how states can use provisional plans of care, including policy and operational considerations, under Section 1915(c), Section 1915(i), Section 1915(k), and Section 1115 of the Social Security Act (SSA). 

Chapter 3: Streamlining Section 1915 Authorities for HCBS 

MACPAC outlines a wide range of authorities that states utilize to deliver HCBS and the varying requirements associated with each. The majority of states create their comprehensive HCBS programs within the framework established by sections 1915(c), 1915(i), and/or 1115 of the Social Security Act; however, there are a wide range of other statutory authorities used to establish HCBS around the country. Though this chapter’s discussion provides a comprehensive discussion of the complexities introduced by the variety of requirements and options within the various statutory sections, MACPAC only makes one recommendation relatively minor in this section: 

  • To reduce administrative burden for states and the federal government, Congress should amend Section 1915(c)(3) and Section 1915(i)(7)(C) of the SSA to increase the renewal period for HCBS programs operating under Section 1915(c) waivers and Section 1915(i) state plan amendments from 5 years to 10 years. 

HCANYS and our colleagues at The Alliance support this recommendation since it would provide more predictable and continuous operations of HCBS around the country. However, as with the prior HCBS recommendation in Chapter 2, we believe that there are ample opportunities to improve and streamline the delivery of HCBS. HCANYS and The Alliance encourage MACPAC, CMS, and Congress to think more broadly and comprehensively about policy changes that could improve the delivery of care. Specifically, that Congress should create a unified, streamlined Medicaid HCBS benefit that provides consistency within and across states. The benefit should have a core set of mandatory services with the option to include additional services. The program should include federal minimum standards of quality and access regardless of whether the state uses fee-for-service or managed care. States should be provided with enhanced Federal matching funds for both administration and services within this benefit. 

HCANYS members can review the full MACPAC March Report here.