Client Alert

Payment Rate Transparency Standards

CMS has finalized new Medicaid and CHIP transparency requirements impacting fee-for-service (FFS) payment rates, managed care payment analyses, and state reporting obligations.

Ensuring Access to Medicaid Services Final Rule Medicaid and Children’s Health Insurance Program Managed Care Access, Finance, and Quality Final Rule

March 2, 2026

4 minutes

Key Takeaways

The requirements established under CMS-2442-F and CMS-2439-F are designed to increase transparency into Medicaid payment methodologies and support monitoring of access to care.

States must publish Medicaid FFS payment rates and conduct comparative payment analyses beginning July 1, 2026.
New transparency requirements apply to HCBS payment rates, interested party advisory groups, and Medicaid managed care payment reporting.
State agencies should begin evaluating current rate-setting processes, reporting systems, and stakeholder engagement strategies to ensure timely compliance.

What State Agencies Need to Know: At a Glance

In May 2024, the Centers for Medicare & Medicaid Services (CMS) published two final rules establishing new Medicaid and CHIP access, payment, and transparency requirements: Medicaid and CHIP Ensuring Access to Medicaid Services (CMS-2442-F) and Medicaid and CHIP Managed Care Access, Finance, and Quality (CMS-2439-F).

Medicaid Rate Development & Transparency Support

Myers & Stauffer assists state Medicaid agencies with developing, analyzing, and implementing compliant payment systems. Our teams support rate calculations, reimbursement methodology reviews, rate schedule development, Medicare comparisons, and publication requirements.

Medicaid Managed Care Oversight & Reporting

Our experienced teams partner with states and CMS to support managed care oversight, including validating MCO-reported data, developing standardized reporting tools, and performing comparative payment analyses to support compliance with federal requirements.

Key Applicability Dates

Effective Dates & Necessary Actions

July 1, 2026

HCBS Payment Rate Disclosure

States must calculate and publish average hourly Medicaid FFS payment rates for applicable HCBS services, including personal care, home health aide, homemaker, and habilitation services. Disclosures must identify geographic and population-based rate variations.

July 1, 2026

Payment Rate Transparency Publication & Comparative Payment Rate Analysis

States must publicly publish Medicaid FFS rates and conduct comparative analyses of Medicaid and Medicare payment rates for specified evaluation and management (E/M) codes. These requirements apply to primary care, obstetrical and gynecological care, outpatient mental health, and substance use disorder services.

July 9, 2024

Interested Parties Advisory Group

States must establish an Interested Parties Advisory Group to provide consultation and recommendations regarding HCBS payment adequacy and access metrics. CMS has delayed enforcement of this requirement until January 1, 2029.

July 9, 2024

Rate Reduction and Restructuring SPA Procedures

States submitting State Plan Amendments (SPAs) that reduce or restructure Medicaid reimbursement rates must include additional analyses demonstrating whether the proposed changes may impact access to care.

First Rating Period Beginning On or After July 9, 2026

Annual Managed Care Payment Analysis

States must require Medicaid managed care organizations (MCOs) to conduct annual payment analyses comparing managed care payments to Medicare and Medicaid FFS benchmarks for specified services.

Key Requirements

Fee-for-Service Payment Rate Transparency

States must publish Medicaid FFS rates on a public-facing website and update published information within 30 days of payment rate changes. Published rates must clearly identify variations by provider type, population, geography, and service components. Requirements include:

Publishing rates for Medicaid providers and services, excluding specified demonstration rates.
Identifying components of bundled rates and value-based payments when based on FFS rates.
Ensuring rate information is organized and understandable for public users.

HCBS Payment Rate Reporting

States must disclose average hourly Medicaid FFS payment rates for applicable HCBS services and convert non-hourly payment methodologies into hourly equivalents. Reporting must include:

Average hourly rates for agency and individual providers.
Geographic and population-based rate differences.
Facility-related costs separately identified from service payments.

Medicaid Managed Care Payment Transparency

States must require MCOs to submit annual payment analyses comparing:

Managed care rates to Medicare rates for applicable E/M services.
Managed care rates to Medicaid FFS rates for applicable HCBS services.

State agencies should evaluate existing rate publication practices, reporting processes, and data systems to identify gaps before implementation deadlines.

Review current Medicaid rate schedules.
Determine whether published rates meet CMS formatting and content requirements.
Identify services requiring additional rate calculations or reporting.

States should establish processes for completing required payment comparisons and stakeholder engagement activities.

Develop standardized templates for required analyses.
Prepare Medicare and Medicaid FFS comparison methodologies.
Establish procedures for MCO reporting oversight.

How Myers & Stauffer Can Help

Nearly 50 Years of Medicaid Expertise

Myers & Stauffer brings decades of Medicaid and Medicare experience supporting states with compliant rate-setting methodologies, payment systems, and transparency initiatives.

Explore Medicaid Rate Setting

We partner with nearly 30 states and CMS to support Medicaid program integrity and oversight, including MCO data validation, reporting tool development, and comparative analysis. Our teams help states navigate CMS requirements through: