Client Alert

Implementation of the Ensuring Access to Medicaid Services (CMS-2442-F) Final Rule: Part 1

Payment Rate Transparency 42 CFR § 447.203(b)(1): Payment Rate Transparency Publication of Medicaid FFS Rates

December 12, 2025

4 minutes

Key Takeaways

Beginning July 1, 2026, state Medicaid agencies must publicly publish and maintain their Medicaid fee-for-service (FFS) payment rates in accordance with the requirements established under 42 CFR § 447.203(b)(1).

Publish all applicable FFS rates: States must make FFS rate schedules readily accessible on a public-facing website, including rates that may not have historically been published.
Provide clear and complete rate information: Published rates must identify applicable variations based on factors such as population, provider type, and geographic location.
Disaggregate bundled and value-based payments: When payment amounts are based on FFS rates, states must identify each component service and its corresponding rate or allocation.
Maintain current rate information: Following the July 1, 2026 implementation date, states must update published rate information within 30 days of approved payment rate changes.

What State Agencies Need to Know: At a Glance

The new Medicaid FFS payment rate transparency requirements go beyond simply posting existing fee schedules online. States should evaluate whether their current rate publications include all applicable FFS rates, clearly identify rate variations, appropriately address bundled and value-based payments, and provide actual payment amounts for formula-based methodologies.

States may also need to update fee schedule templates, operational procedures, websites, and posting policies to meet the new requirements and maintain compliance on an ongoing basis.

Evaluate Payment Rate Transparency Requirements

Review the CMS final rule and Guide for States to understand the scope of the new Medicaid FFS rate publication requirements and identify the rate information that must be made publicly available.

Prepare for Ongoing Compliance

Develop processes for reviewing, updating, and publishing fee schedules, including procedures to ensure rate information is updated within 30 days of approved payment rate changes.

Key Applicability Dates

Stay Ahead

July 1, 2026

Initial Payment Rate Publication

States must publish and make readily accessible applicable Medicaid FFS payment rate schedules on a public-facing website.

Within 30 Days of a Rate Change

Ongoing Rate Updates

After July 1, 2026, states must update published rate information within 30 days of an approved payment rate change.

July 1, 2028

Second Two-Year Update

States should establish a routine process for updating rate publications on an ongoing basis. The second two-year update will occur July 1, 2028, consistent with the broader FFS payment rate transparency requirements.

Understanding the Payment Rate Transparency Requirements

The new requirements under 42 CFR § 447.203(b)(1) establish specific expectations for how states publish Medicaid FFS payment rates.

States must organize published rates in a manner that allows the public to easily understand Medicaid FFS payments. This includes all applicable FFS rates, including rates that states may not have historically published, such as certain provider-specific rates.

The publication requirements exempt Federally Qualified Health Center (FQHC) and Rural Health Clinic (RHC) rates, as well as Certified Community Behavioral Health Clinic (CCBHC) rates under the CCBHC demonstration.

Bundled and Value-Based Payments

When bundled or value-based payments are based on FFS rates, states must identify each component service, along with the applicable rates and allocations.

Certain alternative payment methodologies may also be subject to the publication requirements.

Formula-Based Methodologies

States must publish the actual payment amounts derived from formula-based payment methodologies rather than publishing only the underlying methodology or formula.

Variable Rates

FFS rates that vary based on factors such as population, provider type, geographic location, or other criteria must be clearly identified in each fee schedule publication.

States have flexibility in how they organize and format their FFS rate publications, provided the required information is included and readily accessible.

How Myers & Stauffer Can Help

Recommended Actions

Myers & Stauffer recommends that states begin evaluating their current Medicaid FFS rate publication practices and develop a plan for meeting the payment rate transparency requirements.

Review the final rule and CMS Guide for States to understand the numerous new requirements for Medicaid FFS payment rate publication.

States should assess their current fee schedule publication practices and determine whether existing publications meet the new requirements for rate coverage, accessibility, formatting, and ongoing updates.

The July 1, 2026 implementation date provides an important opportunity for states to evaluate their existing rate publication practices and establish sustainable processes for ongoing compliance. Myers & Stauffer is ready to help states navigate the requirements and develop practical solutions for accurate, accessible, and transparent Medicaid payment rate information.

Rate Setting Expertise
Our teams support state Medicaid agencies with reimbursement rate calculations, rate development, and the preparation of rate schedules for publication.
Payment Rate Analysis
We can assist with evaluating payment rates, preparing comparisons to Medicare, and identifying rate information that may require additional analysis or publication.
Compliance Support
Our experienced team can help states assess current practices, identify gaps, engage stakeholders, and develop processes to support timely compliance with federal Medicaid FFS payment rate transparency requirements.