Health Center Regulatory Issues

Request for Comments on CMS Medicaid Managed Care NPRM

NACHC is pleased to share our draft comments on the recent CMS proposed rule on Medicaid managed care. This rule is the first time since 2002 that CMS has proposed to update the rules governing Medicaid Managed Care Organizations (MCOs.)  As such, it touches on a broad range of issues of direct relevance to health centers and their patients, including but not limited to:

  • The intersection of the 340 program and Medicaid managed care
  • Network adequacy standards for MCOs
  • Whether FQHCs can receive state funding for providing outreach & enrollment assistance to Medicaid MCO enrollees.
  • States’ responsibility to make wrap-around payments directly to FQHCs
  • Credentialing requirements under MCOs
  • Value-based purchasing initiatives
  • Beneficiary protections

Before submitting these comments to CMS, we welcome your comments on our draft. To ensure NACHC has adequate time to consider your input, please send any feedback to Colleen Meiman (, Director of Regulatory Affairs, by Monday July 20.

**Note that the 3-4 highlighted items indicate areas where we are still seeking information ad/or finalizing our recommendations.

In addition, we strongly encourage your organization to submit your own comments on this proposed regulation. Please feel free to adapt or copy the language included in NACHC’s comments to suit your needs; we also encourage you to add examples based on your own experiences.  Note that your comments must be submitted no later than 5 p.m. ET on July 27.  You can submit them electronically by following the “Submit a comment” instructions at

If you have any further questions, please contact Colleen Meiman, Director of Regulatory Affairs at