Client Alert

Implementation of the Ensuring Access to Medicaid Services (CMS-2442-F) Final Rule: Part 5

Understanding Medicaid Fee-for-Service Payment Rate Transparency and SPA Requirements for Rate Reductions and Restructuring

CMS-2442-F Final Rule CMS Guide for States

December 12, 2025

3 minutes

Key Takeaways

The Ensuring Access to Medicaid Services Final Rule (CMS-2442-F) establishes new requirements for states submitting Medicaid State Plan Amendments (SPAs) that reduce or restructure fee-for-service reimbursement rates. States must now demonstrate that payment changes will not diminish beneficiary access to care through new access analyses and reporting requirements.

States must complete access analyses before submitting applicable rate reduction or restructuring SPAs.
CMS established a two-tiered methodology to determine whether reimbursement changes could reduce access to care.
New reporting requirements became effective July 9, 2024, and apply to all Medicaid fee-for-service benefit categories.

What State Agencies Need to Know: At a Glance

The CMS Final Rule replaces the former Access Monitoring Review Plan (AMRP) requirements with a broader framework focused on payment rate transparency. While several provisions become effective in 2026, the Rate Reduction and Restructuring SPA Procedures became effective immediately in July 2024.

Whenever a state proposes reducing Medicaid payment rates—or restructuring reimbursement in a way that could decrease access—it must submit an access analysis alongside the SPA.

Analyze Rate Reduction Requirements

Our team helps states evaluate whether proposed reimbursement changes trigger the new federal access analysis requirements and assists with documenting compliance.

Develop Required Access Analyses

We help agencies compile utilization, provider participation, payment, and beneficiary data needed for CMS submissions.

Key Applicability Dates

Medicaid Fee-for-Service Payment Transparency

July 1, 2026

Payment Rate Transparency Publication begins.

Comparative Payment Rate Analysis required every two years.

Within Two Years of Final Rule

First advisory group meeting required.

Meetings held at least every two years thereafter.

July 9, 2024

Access analyses required for applicable SPAs.

Requirements currently in effect.

When Is an Access Analysis Required?

States must complete an access analysis whenever they submit a Medicaid SPA that:

Reduces payment rates.
Restructures payment methodologies that could reduce access.
Includes reductions to supplemental payments.
May negatively impact provider participation or beneficiary access.

CMS notes that not every payment change qualifies. Many quality incentive payments and alternative payment models that increase reimbursement generally are not considered restructurings requiring analysis.

Initial State Analysis

Most applicable SPAs begin with an initial review demonstrating that:

Medicaid reimbursement remains at least 80% of comparable Medicare rates.
Aggregate Medicaid expenditures decline by no more than 4% for the benefit category.
Public comments do not identify significant access concerns.

If all three conditions are met, no additional analysis is required.

Additional State Analysis

If Tier 1 requirements cannot be met, states must complete a more comprehensive review that evaluates:

Provider participation trends.
Beneficiary utilization trends.
Service utilization over the previous three years.
Potential impacts on access to care.
Public comments and state responses.

CMS provides a standardized Excel workbook for completing these reporting requirements.

How Myers & Stauffer Can Help

Myers & Stauffer has extensive experience supporting Medicaid agencies with reimbursement methodology development, payment rate analysis, stakeholder engagement, Medicare comparisons, supplemental payment evaluations, and CMS reporting. Our multidisciplinary team can help states navigate the new payment transparency requirements while maintaining beneficiary access and ensuring timely SPA approvals.

Email: kristas@mslc.com
Phone Number: 208-378-1400