GHA Submits Comment Letter on The Medicaid Fiscal Accountability Regulation

On Jan. 31, GHA submitted to the Centers for Medicare and Medicaid Services (CMS) a comment letter on the Medicaid Fiscal Accountability Regulation (MFAR).


Important Reminder

GHA continues to work with the American Hospital Association on the hospital industry’s response to the CMS proposed Medicaid Fiscal Accountability Regulations (MFAR). According to both national and state-level analyses, the MFAR could result in severe Medicaid cuts to hospitals and other providers in states like Georgia that rely heavily on IGTs and provider taxes to finance the state share of Medicaid payments. This, in turn, could jeopardize access to health care for millions of Americans. GHA strongly encourages members to ask CMS to rescind the proposed rule by submitting comments prior to the Feb. 1 comment deadline.

GHA has developed a Georgia-specific model comment letter. Simply place the model letter on your hospital letterhead, fill in the highlighted information, and submit the letter electronically via the Federal Register website.

We also urge you to speak with your Congressional delegation, as well as state policymakers, emphasizing that, if finalized, the proposal would:

  • Increase the administrative burden on states with expanded reporting requirements on supplemental payments to Medicaid providers;
  • Significantly restrict the ability of states to use intergovernmental transfers to finance the state share of Medicaid payments;
  • Add new restrictions and review authority for Medicaid provider taxes and limit approval of certain provider taxes like Georgia’s Hospital Provider Payment Program to three years; and
  • Create a greater degree of uncertainty for states and providers in calculating supplemental payments and in terms of what CMS will consider permissible funding sources for the state share of Medicaid payments.

To further aid your advocacy efforts, GHA has put together an analysis of the proposed rule’s potential negative impact in Georgia that has been shared with a number of state policymakers and the Georgia Congressional delegation. Intergovernmental transfers (IGTs) and provider fees account for around 21% of total Medicaid payments or, $730 million, of all Georgia Medicaid state matching fund sources. The proposed rule could have a significant impact on all hospitals, regardless of whether your hospital is currently eligible to make IGTs.

If finalized, the proposal puts at risk $2.3 billion in annual Georgia Medicaid payments to hospitals and other providers financed by IGTs and providers fees. AHA has also made available an MFAR Fact Sheet and infographic of the national impact.


On Nov. 18, 2019, CMS published proposed Medicaid Financial Accountability Regulations. At the request of the hospital community, the comment period was extended to Feb. 1, 2020. This proposed rule:

  • Increases the administrative burden on states with expanded reporting requirements on supplemental payments to Medicaid providers;
  • Significantly restricts the ability of states to use intergovernmental transfers to finance the state share of Medicaid payments;
  • Adds new restrictions and review authority for Medicaid provider taxes and limits approval of certain provider taxes like Georgia’s Hospital Provider Payment Program to three years; and
  • Creates a greater degree of uncertainty for states and providers in calculating supplemental payments and in terms of what CMS will consider permissible funding sources for the state share of Medicaid payments.

GHA has put together an analysis of the proposed rule’s potential negative impact in Georgia which has been shared by a number of state policymakers. Intergovernmental transfers (IGTs) and provider fees account for around 19% or $730 million of all Georgia Medicaid state matching fund sources. If finalized, the proposal puts at risk $2.3 billion in annual Georgia Medicaid payments to hospitals and other providers financed by IGTs and providers fees.