Comment to CMS - Medicaid Fiscal Accountability Regulation (MFAR) | Citizens Against Government Waste

Comment to CMS - Medicaid Fiscal Accountability Regulation (MFAR)

Agency Comments

January 31, 2020

Centers for Medicare and Medicaid Services
Department of Health and Human Services
Dockets Management Staff (HFA-305)
P.O. Box 8010
Baltimore, Maryland  21244-8010


Docket: CMS–2393–P

Proposed Rule - Medicaid Program; Medicaid Fiscal Accountability Regulation (MFAR)


Citizens Against Government Waste (CAGW) is a private, nonpartisan, nonprofit organization representing more than one million members and supporters nationwide.  Founded in 1984 by the late industrialist J. Peter Grace and syndicated columnist Jack Anderson to implement the recommendations of President Ronald Reagan’s Private Sector Survey on Cost Control, also known as the Grace Commission, CAGW’s mission is to eliminate waste, mismanagement, and inefficiency in government.


Medicaid is a federal and state funded program but is administered by the states.  Federal matching funds are available to states for different types of payments that states make.  Some states provide substantial additional payments to providers above what they pay for individual services through Medicaid rates.  The additional payments fall into two categories: disproportionate share hospital (DSH) payments and UPL (upper payment limit) supplemental payments.

The rule is designed to address a proliferation of supplemental payment arrangements that mask or circumvent Medicaid law and regulations with dubious financial arrangements that are driving up taxpayer costs and perverting the system.

CAGW’s complete comments on this rule can be found here.

Issues Topics: 

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