Issue #284
Sellers Dorsey Digest
April 30, 2026
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Summary of Public Comments Submitted in Response to CMS’s CRUSH RFI
Federal News
Healthcare CEOs Testify Before House Ways and Means Committee
Healthcare CEOs convened at the House Ways and Means Committee hearing on April 28 to discuss rising healthcare costs and potential policy options with lawmakers. The CEOs of HCA Healthcare, CommonSpirit Health, and ECU Health were called to testify during this session. Notably, the leaders of these systems indicated that they may be receptive to some site-neutral payment policy in Medicare. This is a large shift from previous efforts from the hospital industry, where previous efforts by Congress to create site-neutral payment policy saw significant pushback. Other topics brought forth by lawmakers included provider consolidation and the 340B drug pricing program. Healthcare CEOs also had suggestions for new policies to reduce hospital costs, which included reducing administrative and regulatory burdens, increasing hospital competition by restricting Certificate of Need Laws, and increasing healthcare coverage (Fierce Healthcare, April 28).
Texas Medicaid Could See CMS Review of Hospice Providers, DME Moratorium According to Dr. Oz
On Tuesday, April 28, Dr. Oz indicated that CMS would turn to Texas to review potential fraud among hospice providers in the state. This follows the agency’s review of hospice fraud in the Los Angeles area. The CMS administrator also noted that Nevada has seen a sizable jump in hospice provider enrollment and highlighted that Nevada, like Florida, has issued a moratorium on new durable medical equipment suppliers. During his message at the Paragon Health Institute event, Dr. Oz suggested that other states may follow Florida and Nevada’s lead by issuing moratoriums on DME provider enrollment. CMS has already issued a national six-month moratorium on DME provider enrollment in Medicare (Inside Health Policy, April 28).
Insurers Tout Efforts to Standardize Prior Authorization Requirements
Following a pledge by 50 insurers to reform prior authorization last year, several insurance companies, including Centene, Cigna, Humana, UnitedHealthcare, and Aetna, announced their voluntary efforts to standardize prior authorization requirements across commercial, Medicare Advantage, and Medicaid lines of business. The insurers state that they have reduced prior authorizations for a variety of healthcare services by about 11% across the board. Industry leaders expect widespread adoption of these voluntary prior authorization standards among additional payers by January 2027 (AHIP, April 24; Modern Healthcare, April 24; Fierce Healthcare, April 24).
CMS Medicaid and CHIP Roadmap Signals State System Changes
As Medicaid and CHIP policy requirements continue to expand through new federal statutes, regulations, and technical guidance, CMS developed the Medicaid and CHIP Policy Implementation Roadmap to help State Medicaid Agencies anticipate how these evolving requirements may affect state policy, operations, and Medicaid Enterprise Systems. Designed as a multi-year planning resource, the roadmap provides an illustrative timeline of selected provisions from major final rules and statutes between 2025 and 2030 that are most likely to create operational or technology-related impacts. CMS emphasizes that the roadmap is not a comprehensive list of every requirement, but rather a strategic reference tool to support proactive implementation planning while states continue to rely on final rules and statutes as the official compliance standard.
The roadmap highlights a phased policy transformation over several years. Early implementation priorities in 2025 and 2026 focus on foundational system and compliance changes such as provider directory standards, access and managed care transparency requirements, quality reporting, beneficiary communication updates, eligibility process reforms, and provisions tied to the Consolidated Appropriations Act and Working Families Tax Cut legislation.
Beginning in 2027, CMS places greater emphasis on person-centered service planning, continuous quality improvement, interoperability, prior authorization transparency, and stronger incident management systems. By 2028 through 2030, implementation priorities increasingly center on Home and Community-Based Services (HCBS), including HCBS quality measure sets, payment adequacy standards, public quality ratings, and expanded electronic oversight systems. Together, these milestones reflect CMS’s push for stronger transparency, modernized systems, quality oversight, and beneficiary protections, requiring states to treat compliance as an ongoing operational priority rather than a one-time policy update (Medicaid, April).
CMS Releases Proposed 2028 HCBS Quality Measure Set
On April 28, CMS published the proposed 2028 Medicaid Home and Community-Based Services (HCBS) Quality Measure Set rule in the Federal Register. The agency is seeking input whether to include 23 mandatory measures in the 2028 HCBS Quality Measure Set. Each state would be required to report on four to five participant-reported measures from each applicable section of the care survey selected by the state; two assessment/case management system measures; and three administrative data measures, all based on the different HCBS populations a state may serve. CMS also proposes that states have the option for CMS to conduct analyses and report on the three administrative measures on the state’s behalf using T-MSIS data. CMS proposes a graduated timeline for states to provide stratified data, including rural and urban status, beginning with 25% of measures in 2028 and ending with 100% of measures, including stratified data, by 2032. The agency is seeking comment on whether the required stratification is feasible and would not cause undue burden or cost. Finally, CMS is soliciting comments on whether to establish a state reporting window, similar to the Adult Core Set, that would open on September 1, 2028, and close on December 31, 2028, or if an alternate schedule is preferred (Federal Register, April 27).
State News
Many South Dakotans at Risk of Losing Medicaid Access as Work Requirements Loom Closer
The South Dakota Department of Social Services estimates that 4% of South Dakota’s Medicaid expansion population are at risk of being disenrolled upon the implementation of federal work requirements next year. Furthermore, an estimate by the Division Chief of Children and Family Services also found that of the 29,504 individuals enrolled in Medicaid expansion at the end of 2025, about 20% could not be determined as meeting mandated exemptions, work requirements, nor community engagement standards. The agency’s assessment does not take into consideration medical frailty, veteran disability status, or volunteer service due to these factors not currently being accounted for in eligibility (South Dakota Searchlight, April 26).
NC General Assembly Passes Medicaid Funding Bill, Creates New Policies
North Carolina lawmakers passed a $319M package to fund the state’s Medicaid program on April 28. Governor Josh Stein is expected to sign the bill into law, as his office has pressed the General Assembly to fund the program, which was expected to run out of money in May without intervention. In addition to funding Medicaid, House Bill 696 will establish a series of oversight provisions, mandate three months of compliance with work requirements ahead of application, and increase eligibility checks for enrollees. Republican lawmakers in the state also provided funding to the state auditor’s office to review the Medicaid division for potential fraud, waste, and abuse (WRAL, April 22; WRAL, April 28).
Colorado Lawmakers Plan to Cap Enrollment on Healthcare Coverage for Immigrants
In Colorado, House Bill 26-1411 may limit the state’s coverage for low-income children and pregnant people without legal status. The program, Cover All Coloradans, was enacted in 2022 and launched in 2025 as a Medicaid look-alike program paid for by the state. Healthcare coverage for this population was expected to be $14.7M in the first full fiscal year but actual costs exceeded $100M, due in part to an unpredictable increase in immigrants coming into the state and a robust outreach program. Colorado is looking to close a $1.5B budget gap, driven in large part by Medicaid and healthcare costs. Cover All Coloradans was subject to heavy debate in the legislature, with lawmakers looking to cap enrollment and limit future growth. According to the Department of Health Care Policy and Financing, the program had about 20,000 children and 8,000 pregnant people enrolled. The most recent fiscal analysis estimates $16M in savings for FY2027 and $30M in savings for each subsequent year. HB 26-1411 is currently in Conference Committee to resolve amendments made by the Senate to cap dental service expenditures and place a limit on total enrollment for children (Colorado Newsline, April 21).
Report from Washington State Shows Prior Authorization Lags Under WISeR Model
A report released by Washington state’s Senator Maria Cantwell found that the WISeR model has increased administrative burden while also potentially hurting patient health outcomes by delaying access to care. The Wasteful and Inappropriate Service Reduction (WISeR) model leverages private contractors to implement artificial intelligence within the prior authorization process for certain procedures under Original Medicare CMS has deemed to be high risk for fraud, like skin and tissue substitutes or arthroscopic lavage for knees. However, since its announcement, the model has faced opposition from provider groups and some lawmakers in Congress. Senator Cantwell’s report includes data from 16 hospitals affiliated with the Washington State Hospital Association and highlighted that the window for prior authorization approval has grown from two weeks to four to eight weeks for procedures under the purview of the WISeR model. The report also noted how the prior authorization denials and subsequent appeals are increasing administrative burden on providers. Finally, the report raises conflict of interest concerns, noting how the private contractors are paid a portion of the dollar value of denied requests that aren’t overturned. Secretary Kennedy stated that his department would work with the senator to fix the issues she highlighted during a Senate Finance Committee hearing last week but maintained that the WISeR model was needed to address fraudulent and wasteful spending in the program (Healthcare Dive, April 24; Fierce Healthcare, April 23).
Nebraska Becomes First State to Launch Medicaid Work Requirements Under OBBBA
A major Medicaid policy shift begins May 1 in Nebraska, where the state will become the first in the nation to implement work requirements for Medicaid expansion beneficiaries under the One Big Beautiful Bill Act. Adults ages 19 to 64 applying for expansion coverage must meet the law’s 80-hour monthly work or community engagement requirement unless they qualify for a medical or hardship exemption, while current beneficiaries will be assessed at renewal. To support implementation, Nebraska released a 295-page exemption framework outlining which conditions may qualify individuals as medically frail, including serious physical illnesses, behavioral health disorders, developmental disabilities, substance use disorders, pregnancy complications, severe injuries, and functional limitations. The state will initially rely on self-attestation before shifting toward more automated verification as federal guidance develops. Nebraska also established temporary hardship exemptions for hospitalization, nursing home stays, treatment-related travel, and residence in emergency or high-unemployment areas. As the first state moving forward before CMS finalizes several national implementation details, Nebraska’s rollout is expected to serve as an early test case for how states may structure exemptions, verification, and compliance under the new Medicaid work requirement law (Inside Health Policy, April 28).
SPAs and Waivers
SPAs
- Eligibility
- Ohio (OH-26-0003, effective January 1, 2026): Removes dual eligible exclusions from the Alternative Benefit Plan (ABP), following the implementation of the Next Generation MyCare Ohio Plan.
- Services
- California (CA-26-0012, effective January 1, 2026): Updates the behavioral health treatment (BHT) section.
- California (CA-26-0013, effective January 1, 2026): Removes outdated financial thresholds of durable medical equipment (DME).
- Payment
- Florida (FL-24-0007, effective July 1, 2024): Updates payment methodology for outpatient hospital services.
- North Dakota (ND-26-0003, effective January 1, 2026): Establishes payment methodology for therapeutic leave days for Psychiatric Residential Treatment Facilities.
- Texas (TX-25-0024, effective September 1, 2025): Establishes payment methodology for personal attendants, through an increase of an average of $13/hour.
- Utah (UT-26-0002, effective July 1, 2026): Establishes an annual update the base value of licensed nursing facility beds through an inflation adjustment factor, and specifies the maximum allowable age of a nursing facility.