The Centers for Medicare and Medicaid Services (CMS) is overseeing a significant shift in the transparency and oversight of Medicaid managed care programs, with states now required to submit comprehensive annual reports detailing plan-level data. This modern reporting requirement, formalized in regulations updated in 2024, builds upon earlier changes dating back to 2016 and comes after a period of relaxed requirements under the previous administration.
Currently, managed care represents the dominant model for Medicaid delivery, covering approximately 78% of beneficiaries – over 66 million individuals as of July 2024 – and accounting for 50% of total Medicaid spending, exceeding $458 billion in fiscal year 2024. States contract with more than 280 individual Medicaid managed care organizations (MCOs), a mix of private for-profit, private non-profit, and government-run plans. These contracts frequently involve billions of dollars annually.
The new Managed Care Program Annual Report (MCPAR) is designed to improve monitoring, oversight, and transparency, functioning alongside other existing reports. While states have historically held primary responsibility for overseeing managed care plans, federal rules have evolved, and publicly available performance data has often been limited and inconsistent. The 2024 regulations aim to address these shortcomings with provisions focused on beneficiary protections, access to care, and program oversight.
Despite some easing of managed care requirements in 2020 by the prior administration, the reporting requirements remained intact. CMS continues to publicly post the state-submitted managed care reports on Medicaid.gov. The reports are expected to provide policy makers with more detailed metrics for analysis, though initial findings are still forthcoming.
The implementation of these changes coincides with a period of significant transition for Medicaid, including the completion of state Medicaid agencies’ post-pandemic eligibility redeterminations. As of July 2024, nearly 2.2 million applications for Medicaid and CHIP were submitted directly to states, an 8.5 percent increase from the previous month. The variations in how states structure their managed care arrangements – determining which populations and services are included – continue to present challenges for consistent oversight and comparison.
It remains uncertain whether the current administration will seek to revise or roll back any provisions included in the 2024 managed care final rules, leaving the future direction of federal oversight in a state of flux.
