CMS Finalizes Medicaid Managed Care Payment Rate Transparency Requirements
CMS Final Rule (CMS-2439-F) introduces new Medicaid managed care payment rate transparency reporting requirements for states beginning with rating periods on or after July 9, 2026. Learn what the rule requires and how early preparation can help ensure compliance.
Key Takeaways
The Centers for Medicare & Medicaid Services (CMS) has finalized new Medicaid managed care payment rate transparency requirements under the Medicaid and Children’s Health Insurance Program (CHIP) Managed Care Access, Finance, and Quality Final Rule (CMS-2439-F). These requirements are designed to improve transparency around managed care payment rates, monitor access-to-care barriers, and provide CMS with greater insight into payment adequacy across Medicaid managed care programs.
What State Agencies Need to Know: At a Glance
On May 10, 2024, CMS published the Medicaid and CHIP Managed Care Access, Finance, and Quality Final Rule (CMS-2439-F), establishing new payment rate transparency standards under 42 CFR §438.207. The regulation requires states to collect standardized payment information from managed care plans, evaluate payment rates across designated service categories, and submit annual reporting to CMS as part of the Network Adequacy and Access Assurances Report (NAAAR).
These reporting requirements are intended to improve transparency and help identify payment-related barriers that may affect beneficiary access to care.
Compare Managed Care Payments
Managed care payment rates must be analyzed against Medicare payment rates for designated evaluation and management (E/M) services and against state’s Traditional Medicaid payment rates for specified home- and community-based services.
Validate and Report Results
States must review managed care plan submissions, validate supporting documentation, submit statewide payment percentages to CMS, and publish the completed report within 30 calendar days of submission.
Medicaid Managed Care Payment Rate Transparency Requirements
May 10, 2024
CMS published the Medicaid and CHIP Managed Care Access, Finance, and Quality Final Rule (CMS-2439-F), establishing Medicaid managed care payment transparency requirements.
States should begin planning implementation activities, including data collection strategies and reporting processes.
July 9, 2026
The requirements become applicable beginning with the first Medicaid managed care rating period on or after this date.
Managed care plans should begin producing payment analyses for applicable reporting periods.
Annual Reporting
Payment analyses must be completed annually and any time there is a significant change.
States must submit results through the Network Adequacy and Access Assurances Report (NAAAR) and publish their reports within 30 calendar days of CMS submission.
Required Payment Analyses
States must ensure managed care plans perform payment analyses for the following service categories, grouped by which benchmark rate applies:
Compared to Medicare FFS rates:
Compared to Medicaid FFS rates:
Separate payment totals and percentages must be reported for each applicable service type. Adult and pediatric services must be reported separately when payment percentages differ. Payments where the managed care plan is not the primary payer, along with services provided by Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs), are excluded from the analysis.
State Reporting Responsibilities
In addition to collecting payment analyses from managed care plans, states are responsible for:
Recommended Actions
Early Preparation Reduces Risk
States have an opportunity to prepare before mandatory reporting begins. Early pilot testing allows agencies to identify data quality issues, resolve reporting inconsistencies, and establish repeatable validation processes before official CMS submissions are required.
Organizations that begin planning now will be better positioned for accurate, timely, and compliant reporting.
Reporting Timeline by Managed Care Contract Year
The Payment Rate Transparency data will be included as a segment of the established Network Adequacy and Access Assurances Report (NAAAR) with a due date that depends on the managed care program’s contract year. CMS established staggered reporting timelines so states begin reporting after completing the applicable rating period.
|
Contract Year of the Managed Care Program |
Rating Periods for Required Reporting |
Next NAAAR Due |
|---|---|---|
|
August – July |
8/1/2026 – 7/31/2027 |
1/27/2028 |
|
September – August |
9/1/2026 – 8/31/2027 |
2/27/2028 |
|
October – September |
10/1/2026 – 9/30/2027 |
3/28/2028 |
|
January – December |
1/1/2027 – 12/31/2027 |
6/28/2028 |
|
April – March |
4/1/2027 – 3/31/2028 |
9/27/2028 |
|
July – June |
7/1/2027 – 6/30/2028 |
12/27/2028 |
How Myers & Stauffer Can Help
While most states have ample time before report submission is required to CMS, we encourage using this period to pilot data collection and analysis efforts. When similar requirements were implemented for Medicaid FFS (effective July 1, 2026), they proved more complex than many clients anticipated. Being proactive will help states identify data inconsistencies, address reporting challenges from managed care plans, and establish best practices for data evaluation early in the process. Early preparation will be key to ensuring a smooth and successful first submission to CMS.
States must mandate that managed care plans complete payment analyses annually and submit supporting documentation in a format specified by the state. To support states in complying with the requirements, Myers & Stauffer has developed a comprehensive template to capture Medicaid managed care payment data, reprice it according to applicable Medicare or Medicaid FFS fee schedules, and aggregate the data for CMS reporting.
Additionally, we recommend, and can assist with, validating the data submitted by the managed care plans against other sources, such as encounter data, financial records, other documentation or claims samples, to ensure accuracy and consistency before submission to CMS and publication on the state’s website.
Myers & Stauffer partners with nearly 30 states and CMS in ensuring proper oversight of managed care plans and compliance with CMS regulatory requirements. Our experienced teams are ready to support states in ensuring timely compliance with the federal rate transparency requirements. Explore our related alert for more information.
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