Comments on the Provider Tax Proposed Rule

On September 21, the MLTSS Association submitted comments on CMS's proposed rule regarding provider taxes. Our comments center on the principle that provider taxes play an instrumental role in supporting payment rates for underserved populations, including individuals receiving Long Term Services and Supports (LTSS). Additionally, our comments offer key considerations for CMS regarding the timeline and implementation of its proposals, as well as the specific impacts on individuals receiving LTSS. We recommend that CMS provide guidance and technical assistance to states and MCOs to support successful implementation of these proposed changes. This includes specific support and recommendations around calculating the Indirect Hold Harmless Threshold to nine decimal places, the interim Indirect Hold Harmless Threshold process, and the addition of new provider classes.

Read the Comments