Client Alert

Implementation of the Ensuring Access to Medicaid Services (CMS-2442-F) Final Rule: Part 2

December 12, 2025

5 minutes

Key Takeaways

The Medicaid FFS payment rate transparency requirements under CMS-2442-F require states to publicly compare Medicaid payment rates for specified services to Medicare rates. Beginning July 1, 2026, states must publish their first comparative payment rate analysis for CY 2025 rates and include detailed information on payment rates, claims, and beneficiaries. Understanding these Medicaid payment rate transparency requirements can help states prepare accurate analyses and meet federal compliance deadlines.

Publish comparative rate analyses: States must publish Medicaid payment rates as a percentage of the corresponding Medicare non-facility rates for specified Evaluation and Management (E/M) codes.
Include detailed utilization data: Analyses must include the number of Medicaid-paid claims and Medicaid beneficiaries who received each specified service during the applicable calendar year.
Update analyses every two years: Following the initial CY 2025 analysis, states must update and publish their comparative analyses at least every two years in accordance with CMS requirements.

What State Agencies Need to Know: At a Glance

States should begin planning now to ensure the data, methodology, and reporting processes needed for the comparative payment rate analysis are accurate and well documented. The requirements involve more than publishing payment rates—they require states to compare Medicaid rates with Medicare rates and provide supporting utilization information in a publicly accessible format.

Identify Applicable Services

CMS has identified 68 E/M codes for the CY 2025 comparative analysis, covering primary care, obstetrical and gynecological care, and outpatient mental health and substance use disorder services. States should confirm the applicable codes and Medicaid payment rates used in their analysis.

Prepare and Validate Data

States must report Medicaid payment rates alongside the corresponding Medicare non-facility rates and include claims and beneficiary counts. States with payment rate variations must also account for differences by population, provider type, and geographic location, as applicable.

Background: Medicaid FFS Payment Rate Transparency Requirements

Payment Rate Transparency 42 CFR § 447.203(b)(2) and (3): Comparative Payment Rate Analysis Publication On May 10, 2024, the Centers for Medicare & Medicaid Services (CMS) published a final rule titled: Medicaid and Children’s Health Insurance Program (CHIP) Ensuring Access to Medicaid Services (CMS-2442-F). As we previously summarized in our May 2024 client alert , the final rule rescinds the existing access monitoring review plan (AMRP) requirements at 42 CFR § 447.203(b) and replaces them with new requirements for Medicaid fee-for-service (FFS) payment rate transparency. To assist states in complying with these requirements, in July 2024, CMS published a Guide for States titled Ensuring Access to Medicaid Services – A Guide for States to the Fee-For-Service Provisions of the Final Rule . The Guide for States outlines comprehensive instructions relating to these requirements. We have included below a table from the Guide outlining the key provisions and applicability (compliance) dates.

This Client Alert Addresses Part 2 – Comparative Payment Rate Analysis Publication

By July 1, 2026, in addition to states publishing their Medicaid FFS payment rate schedules as required by 42 CFR § 447.203(b)(1), states must also compare Medicaid rates for certain services to Medicare rates and publish the results on their Medicaid agency websites.

Key Comparison and Publication Requirements

States must compare Medicaid payment rates for certain CMS-specified Evaluation and Management (E/M) codes to the corresponding Medicare rates. This includes codes associated with primary care, obstetrical and gynecological care, and outpatient mental health and substance use disorder services. States must perform their first comparative rate analysis for Calendar Year (CY) 2025 rates. Subsequent analyses must be updated and published at least every two years, by July 1 of the second year following the latest update. For the CY 2025 comparative analysis, CMS has identified a total of 68 E/M codes. CMS has published the E/M codes for the CY 2025 comparative analysis on the Medicaid.gov website. If Medicaid rates vary within the analysis, the state must separately identify payment rates by population (pediatric and adult), provider type, and geographical location as applicable. The analysis must present the Medicaid payment rate as a percentage of the Medicare non-facility rate for each specified code. For each code, the analysis must also include the number of Medicaid-paid claims and the number of Medicaid beneficiaries who received the service during the designated calendar year.

How Myers & Stauffer Can Help

Supporting Accurate and Transparent Rate Comparisons

Myers and Stauffer has nearly 50 years of Medicare and Medicaid knowledge about required principles that must be followed to set rates and develop payment systems.

For many of our rate setting engagements, our procedures include calculating reimbursement rates, developing rate schedules for publication, preparing comparisons to Medicare, facilitating stakeholder engagement, and other activities that support accurate and transparent reimbursement rates.

Our experienced team is ready to support states in ensuring timely compliance with the federal rate transparency requirements.

Reviewing Medicaid FFS payment rates and applicable CMS requirements.
Preparing Medicaid-to-Medicare payment rate comparisons.
Analyzing claims and beneficiary utilization data.
Identifying rate variations by population, provider type, and geography.
Developing rate schedules and supporting documentation for publication.
Supporting states with ongoing compliance and future comparative rate analyses.