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White paper

Final Rule CMS-2439-F: Medicaid medical loss ratio standards

1 August 2024

The Centers for Medicare and Medicaid Services (CMS) in May finalized updates to the Medicaid medical loss ratio (MLR) reporting standards. This white paper delves deeper into specific aspects of the modifications, including an overview of the major regulatory changes and compliance timelines, with an appendix summarizing the effective dates. The paper’s main sections include discussion of the following:  

  • Inclusion of state-directed payments in MLR calculations
  • Increased transparency requirements for provider incentive arrangements and provider overpayments
  • Prohibited costs in quality improvement activities (QIA)
  • Expanded QIA allocation methodology 
  • Key implementation considerations for state Medicaid agencies 

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About the Author(s)

Paul Houchens

Amber Kerstiens

Amber Kocher

Casey Szulc

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