CMS Shut-Down Plans for the Medicare and Medicaid Programs
CMS has released information on Medicare and Medicaid program activities that will continue during the lapse in federal appropriations that began Oct. 2025.
CMS also indicates it will have sufficient funding for Medicaid to fund the first quarter of FY 2026, based on the advance appropriation provided for in...
New IHS Contracting Policies May Impede Care at IHS-Operated Facilities
New federal policies for contracting are creating additional barriers to providing health care in IHS-operated facilities. IHS operates roughly 20 hospitals and dozens of outpatient facilities nationally, often in areas that are remote. The IHS already faced serious challenges - Congress has generally funded the IHS at only one-half of its need,...
CMS’s Relaxation of the “Four Walls” Requirement Provides Tribal Health Programs with Greater Flexibility to Develop Their Health Care Programs
The Centers for Medicare and Medicaid Services (CMS) has indicated that it has approved Medicaid State Plan amendments for Minnesota, New Mexico, Oregon, South Dakota, Washington, and Wyoming that confirm Medicaid coverage for clinic services provided by tribally-operated health care programs beyond the physical clinic site, including in homes, schools, and other appropriate...
Tribal Health Programs May Be Missing Opportunities to Recover Costs of Operating Their Clinics and Programs
The California Medi-Cal program offers Tribes and Tribal programs a way to receive payments for many administrative activities they perform in providing healthcare to Medi-Cal enrollees. Many Tribes and Tribal organizations are already providing these activities, but are not being reimbursed for them. Examples of activities that may qualify for reimbursement include:
Recent Developments Point to Increased Attention to PACE Organizations from Regulators in California
PACE organizations in California may soon see an increase in the level of oversight activity from state regulators.
PACE, which stands for the Program of All-Inclusive Care for the Elderly, is a Medicare and Medicaid program that helps older adults who require a nursing home level of care remain...
California Medi-Cal Guidance on Implementing Traditional Health Care Practices Benefit
Tribal health programs and Urban Indian Organizations in California that want to provide traditional health care practices to Medi-Cal members will likely want to review the Department of Health Care Services’ most recent guidance on the topic, DHCS Behavioral Health Information Notice 25-007 and attachments. The guidance is lengthy and addresses, among...
California Proposed Asset Limit for Medicaid Impacts Most Vulnerable Enrollees and Their Providers
Although the California Department of Health Care Services' May 2025 budget summary proposes a limit of no more than $2000 in countable assets for persons in Medi-Cal, the asset limit would apply only to some -- not all -- Medi-Cal enrollees and applicants. The proposed asset limit would apply, according to the...
HHS Signals Roll Back of Public Participation in Developing Federal Regulations
According to a notice made public Feb. 28, 2025, the U.S. Department of Health and Human Services is reversing a 1971 policy decision whereby HHS voluntarily solicited the public’s views before issuing regulations related to its programs, even if it wasn’t required to. Buckle up — you can expect to see the...
Responding to Requests from Law Enforcement for Patient and Client Information
Recent changes in immigration enforcement policy that give immigration officials greater latitude to conduct enforcement activities at hospitals and other health care facilities should prompt health care providers to review their policies and trainings for responding to requests for information from law enforcement agencies. Many federal and state law enforcement agencies regularly...
Can a federal agency terminate a grant if the agency determines that the grant no longer furthers an agency’s priorities?
That question has come up often since the OMB memorandum issued last week that directed federal agencies to suspend funding for a host of federal programs while the programs are reviewed in the light of recent Executive Orders. Federal courts will now grapple with broad constitutional and administrative law issues about the...