MLTSS Association Submits Comments on the Preserving Medicaid Funding for Vulnerable Populations-Closing a Health Care-Related Tax Loophole Proposed Rule

On July 14^th, the MLTSS Association submitted comments on the Preserving Medicaid Funding for Vulnerable Populations-Closing a Health Care-Related Tax Loophole Proposed Rule. In our comments, we expressed appreciation for CMS’ efforts to strengthen the oversight and quality of Medicaid programs. Our comments offered key considerations for CMS on the timeline and implementation of its proposals, as well as specific impacts on individuals receiving LTSS. We expressed overarching concern over the timelines proposed in this rule, and the administrative burden placed onto states.

The MLTSS Association recommended the following changes to this proposed rule: 

1. CMS extend the transition period to three years, regardless of a state’s current waiver approval status. 

2. CMS provide clear implementation guidance and robust technical assistance to states that will need to amend existing waivers or financing structures in response to the rule. 

3. CMS postpone the finalization of this proposed rule, to the extent possible under current laws, until further research is conducted on how states utilize provider-related taxes, comprehensive data is gathered, and the potential consequences of the rule are assessed. 

Read the Letter