Issue #239
Sellers Dorsey Digest
June 5, 2025
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Medicaid Work Requirements and Community Engagement Playbook: Key Considerations for States, Health Plans, and Solution Partners
As federal discussions around Medicaid work requirements and community engagement gain traction, stakeholders must be ready to act fast. Our newest playbook offers strategic guidance for designing, implementing, and evaluating these policies—drawing on lessons from past efforts and insights from former Medicaid Directors. Get ahead of the curve with a thoughtful, compliant approach.
News
News
CMS Budget Justification Released, Details Administrative Reductions
- According to the CMS budget justification document released on May 30, the Grants to States for Medicaid account would receive a $57.5B increase in President Trump’s FY2026 proposed budget. However, federal matching funds for state and local administrative expenses would be $1.2B lower compared to FY2025. The Trump administration is requesting an additional $58.5B, totaling $733B, for federal Medical Assistance Payments (MAP), using estimated 2025 expenditures. If the budget is passed as written, states could see a loss of federal funding for Medicaid management information systems, fraud control units, enrollment verification systems, and staff salaries and benefits among other items. The budget justification noted that 1115 waivers should be “refocused and strengthened” and be budget neutral with focuses on chronic disease prevention, home and community-based services, and enrollment integrity along with strong oversight, monitoring, and evaluation. CMS plans to renew the Performance Metrics Databases and Analytics system for 1115 waivers and consolidate the number of state plan amendment processing systems. In line with the administration’s “skinny budget” released on May 2, HHS is expected to be reorganized, with some Health Resources and Services Administration programs merging under CMS along with the Administration for a Healthy America (Inside Health Policy, May 30).
CMS Innovation Center Extends, Revises Kidney Care Choices Model
- The CMS Innovation Center announced it would extend three out of four tracks within the Kidney Care Choices (KCC) Model through 2027. The financial methods in the model will change to improve sustainability starting in 2026, while one track of the model will end December 2026, the Kidney Care First option. The KCC Model, launched in January 2022, started with 93 participants. Early results of the program showed improvements in certain quality metrics like Optimal End State Renal Disease (ESRD) Starts and home dialysis rates. Despite these improvements, the model lost $304M in 2023. Other changes coming to the program include the option for more U.S. territories to host participants in the program, more options in different tracks to achieve discounts for chronic kidney disease benchmarks, rescinding the $15,000 payment per successful transplant over three years, and reducing capitated payments. This comes as the CMS Innovation Center has shifted its priorities to focus on chronic disease prevention and supporting the Make America Healthy Again initiative (Fierce Healthcare, May 27; CMMI, May 27).
CMS Director Submits Resignation
- CMS Director and Deputy Administrator Drew Snyder resigned on Monday, June 2. Former North Dakota Medicaid Director Dr. Caprice Knapp will be stepping in as interim acting director of CMS. She currently serves as the Medicaid counselor to RFK Jr. and was previously a member of the Panel of Health Advisors in the Congressional Budget Office (Politico Pro, June 2).
Hospitals Face New Questions on Gender-Affirming Care
- The Trump administration took additional actions last week to further its policies related to gender-affirming care for children, reaching out to hospitals and healthcare organizations with letters expressing concern and requesting detailed information. Health and Human Services Secretary RFK Jr. sent a letter to providers and state medical boards referencing a recent departmental evidence review. In the letter, he suggested that “some gender-affirming treatments may carry risks” and asked providers to “reconsider their current protocols.” He also indicated that new policies may be introduced to further regulate this area of care. Later that day, CMS Administrator Mehmet Oz contacted specific hospitals that offer gender-affirming care to minors, asking them to share how they obtain informed consent, how they track potential outcomes (including for youth who later choose to detransition), and how federal funding is used for such procedures (X, May 28; CMS, May 28; Fierce Healthcare, May 29).
CMS Looks to Revitalize Health IT Systems Ahead of Medicaid Work Requirement Implementation
- In an interview with Politico, CMS Administrator Mehmet Oz stated that the agency will be looking to revitalize health IT infrastructure and create a centralized repository of the various data CMS collects. Oz expressed that this effort could help ease the administrative burden states may face in implementing Medicaid work requirements. CMS is expected to release “minimal viable products” that will be required for the system update within a year. On May 16, CMS issued a request for information (RFI) for stakeholders in the private sector to help the agency in modernizing the system, though work requirements are not explicitly mentioned. Comments are due June 16 (Politico, June 1; Inside Health Policy, June 2).
Federal Regulation/Guidance
HHS Budget Proposal Shifts Key Drug Program to CMS
- The Department of Health and Human Services (HHS) is proposing a significant reorganization that would phase out the Health Resources and Services Administration (HRSA) and shift its responsibility for oversight of the 340B Drug Pricing Program to the Centers for Medicare and Medicaid Services (CMS). The 340B program, which helps safety-net providers like hospitals and community health centers access discounted outpatient drugs, has been managed by HRSA since 1992. Under the new plan, CMS would take over in 2026 with a proposed $12M budget, matching what HRSA currently receives for the program. Supporters say the change could improve accountability and simplify oversight, as CMS already manages several federal drug programs. However, some worry it could bring stricter compliance requirements for providers. The reorganization is part of a broader effort under the Healthy America agenda, led by HHS Secretary RFK Jr. It remains unclear what changes require executive action versus congressional approval (Modern Healthcare, June 2).
HHS and CMS Rescind 2022 EMTALA Guidance on Pregnancy Care
- The U.S. Department of Health and Human Services (HHS) and the Centers for Medicare & Medicaid Services (CMS) have withdrawn 2022 guidance on emergency care for pregnant patients, stating it no longer reflects the current administration’s policy. While the specific guidance is being rescinded, CMS indicated it will continue enforcing the Emergency Medical Treatment and Labor Act (EMTALA), which ensures emergency care for all patients, including pregnant individuals facing serious health risks. The agencies also claim this move will reduce legal confusion created by the previous administration’s actions (CMS, June 3).
News
News
CVS and Cigna File Suits Against Arkansas PBM Divestment Law
- Following Arkansas Governor Sarah Huckabee Sanders signing HB1150 into law in April, CVS Health and Cigna have filed separate lawsuits to prevent the state from banning PBMs from holding pharmacy licenses within the state. If the act goes into effect next year, both payers will have to cease or divest some of their operations in Arkansas. Currently Cigna’s Express Scripts has 25 non-resident pharmacy licenses in the state. CVS’ Caremark would also be forced to close down its mail order, specialty pharmacy services, and 23 retail pharmacies within the state (Health Payer Specialist, May 30; Arkansas Advocate, May 29).
New Vermont Law Targets Drug Prices and Insurer Stability
- Vermont lawmakers passed two significant healthcare bills aimed at addressing rising healthcare costs and stabilizing the state’s struggling insurance system. House Bill 266 caps hospital markups on certain high-cost, hospital-administered drugs, like those used for cancer and autoimmune diseases at 120% of their average sale price, as determined by CMS’s 340B drug-pricing program. The bill also prohibits hospitals from increasing prices on other services or medications to make up for revenue losses due to the cap. Green Mountain Care Board Chair, Owen Foster, noted that Vermont hospitals currently have some of the highest drug markups in the country, sometimes charging 50 to 70 times the average price. H.482, also passed by the legislature and sent to Governor Phil Scott, empowers regulators to reduce hospital reimbursement rates if a health insurer is at risk of insolvency. The move is in response to the financial crisis facing Blue Cross Blue Shield of Vermont, which covers about one-third of the state’s population and is nearing bankruptcy due to surging claims. If signed, H.266 would be the first law in the U.S. to cap hospital drug markups, potentially serving as a model for other states seeking to curb healthcare costs and protect patients from excessive pricing (Health Payer Specialist, June 2; WCAX, May 30).
Medicaid Program Tackling Food & Housing Faces Shutdown in NC
- North Carolina’s Healthy Opportunities Pilot, a first of its kind Medicaid program addressing nonmedical needs like food, housing, and transportation, will end July 1 due to budget cuts. Since 2022, the program has served nearly 30,000 residents across 33 counties, showing early signs of success, including reduced ER visits and healthcare costs. Despite promising data, including savings of up to $85 per person monthly and decreased hospitalizations, lawmakers say they haven’t seen enough justification to continue the $175M program. The North Carolina Department of Health and Human Services (DHHS) noted that continuing the program in the face of a lack of secure funding as fiscally irresponsible, warning it could leave service providers and community partners with unpaid costs and destabilize local systems. Stakeholders expressed disappointment, noting the program’s impact on low-income residents, farmers, and families displaced by disasters like Hurricane Helene. Democratic lawmakers plan to advocate for renewed funding, arguing the pilot needs more time to show long-term results (North Carolina Health News, June 3).
Waivers
Waivers
- 1115(a)
- Florida
- On May 16, Florida submitted a request for a new five-year 1115 demonstration titled, “Florida Health Care Workforce Sustainability.” The state is requesting authority to create and expand training programs to strengthen Florida’s health care workforce to meet the anticipated demand of the growing and aging population, including those in Medicaid. The programs will focus on provider certification, training, and student loan repayment for eligible qualified providers and facilities that operate in medically underserved areas. The demonstration is not expected to impact Medicaid program eligibility, enrollment, or service delivery. Florida is the first state to seek federal support for a standalone 1115 demonstration for health care workforce innovation. The federal public comment period will be open from June 2 through July 2.
- Florida
SPAs
- Administrative
- North Dakota (ND-25-0011, effective April 1, 2025): Extends the Recovery Audit Contractor (RAC) exemption until March 31, 2027.
- Wyoming (WY-25-0003, effective July 1, 2025): Extends the Recovery Audit Contractor (RAC) exemption until June 30, 2027.
- Payment
- Louisiana (LA-25-0002, effective July 1, 2025): Implements a $50 per encounter add-on amount for Federally Qualified Health Centers (FQHCs) in addition to the Prospective Payment System (PPS) rate.
- Maryland (MD-25-0007, effective February 19, 2025): Adds an inter-agency agreement between the state’s Medicaid program and the Office of HealthCare Quality (OHCQ).
- New Hampshire (NH-25-0002, effective January 1, 2025): Updates nursing facility reimbursement procedures for rate setting following changes in ownership.
- New Hampshire (ND-25-0007, effective January 1, 2025): Updates the Medicaid Quality Improvement Program (MQIP) for private and non-state government owned and operated facilities, regarding quarterly pool amount and total Medicaid day counts.
- New Jersey (NJ-25-0002, effective March 1, 2025): Adds payment methodology for the Opioid Treatment Program (OTP) delivery and provision of Methadone medication assisted treatment (MAT) within long-term care and rehabilitation settings.
- Texas (TX-25-0016, effective June 1, 2025): Updates payment methodology for High-Cost Clinician Administered Drugs (HCCADs) and biologics, human breast milk processing storage and distribution, and long-acting reversible contraception (LARC) to be filed on separate outpatient claims. The HCCAD non-risk payment will depend on the fee-for-service reimbursement rate, with the fee schedule representing the upper payment limit.
- Services
- Connecticut (CT-25-0014, effective June 1, 2025): Makes changes to the excluded drug list, such as allowed FDA approved weight loss medication and approved substitutions, as well as coverage of select medically necessary hair growth, cosmetic, and over the counter (OTC) drugs.
- Nevada (NV-25-0008, effective January 1, 2025): Adds community health representatives as reimbursable providers solely through Tribal Health Clinics that operate under the Indian Self-Determination and Education Act of 1975. Specifies provider qualifications, covered services, and limitations.
- Washington (WA-25-0003, effective July 1, 2025): Provides coverage for eligible juveniles who are pending disposition of charges in compliance with the Consolidated Appropriations Act of 2023.
- Washington (WA-25-0006, effective July 1, 2025): Adds Certified Anesthesiologist Assistants and Dental Therapists to the Other Licensed Providers category.
Navigating Child Welfare Agencies: A Quick-Access Guide for Stakeholders
News
Navigating Child Welfare Agencies: A Quick-Access Guide for Stakeholders
- Navigate the child welfare landscape with ease—Sellers Dorsey experts created an interactive map that offers quick, state-by-state access to child welfare agency contacts, program structures, and key resources. It’s the perfect tool for providers, vendors, MCOs, and agencies seeking to connect and collaborate.
Sellers Dorsey Appoints Jennifer Duke as Chief Growth Officer
- Sellers Dorsey has named Jennifer Duke as its new Chief Growth Officer, an important milestone in advancing the Firm’s mission to expand its reach and deepen its impact across the healthcare landscape. With nearly 20 years of experience leading innovation, business growth, and strategic transformation, Duke brings a proven track record of aligning visionary strategies with measurable outcomes.