January 29, 2008

n4a Submits Comment Letter to CMS Requesting Rule Changes on Targeted Case Management Be Withdrawn

Advocates are Encouraged to Send Letters to CMS before the February 4th Deadline

As reported earlier, the Centers for Medicare and Medicaid Services (CMS) has published an interim final rule to govern targeted case management services under Medicaid (Federal Register, December 4, 2007, Vol. 72, No. 232, 68077-68093). The rule, which goes into effect on March 3, 2008, was issued to update regulations in response to legislative changes in Section 6052 of the Deficit Reduction Act of 2005 (DRA) meant to clarify targeted case management services. However, n4a believes that the CMS rule changes go beyond congressional intent for the DRA provision and would do serious damage to state level efforts to establish Medicaid single point of entry targeted case management systems.

n4a has submitted a comment letter to CMS stating that the rule changes would seriously undermine state level efforts to streamline and provide more efficient and cost-effective targeted case management systems and home and community-based services through the aging services network under Medicaid. The letter urges CMS to withdraw the Interim Final Rule changes, many of which do not serve the best interests of consumers, and reconsider the regulations. To review the full comment letter visit: http://www.n4a.org/cap/Comment_letter_CMS_IFR_TCM_1.29.08.pdf .

Take Action: There is Still Time to Provide Comments to CMS

To review all the rule changes visit: http://www.n4a.org/cap/CMS_IFR_TCM_12-4-07.pdf. If these rule changes are of concern to you, it is critical that you express your concerns directly to CMS in writing. Comments are due to CMS no later than 5 p.m. on February 4, 2008. Advocates are encouraged to use n4a's comment letter as a template and customize it with information on how the rule changes would impact case management systems offered in your state. Specific instructions on how to submit comments to CMS are included in the Federal Register notice. Agencies submitting comments to CMS should be sure to share the letters with members of their House and Senate congressional delegation.

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For more information, please contact Amy E. Gotwals (agotwals@n4a.org) or K.J. Hertz (khertz@n4a.org), n4a’s Public Policy and Legislative Affairs staff. 202-872-0888.