Legislative memo — Medicaid Integrity, Access, and Accountability Act of 2025
Purpose: Modernize Medicaid to satisfy fiscal conservatives’ demands for integrity and efficiency while advancing progressives’ goals for access and equity — with measurable outcomes, transparent reporting, and budget discipline.
🔍 Eligibility integrity (SSA §1902(e))
- Real‑time verification at application/renewal using wage, death, and benefits databases.
- Monthly cross‑checks; immutable audit logs of determinations.
- Public monthly reporting: redeterminations, terminations, error rates.
💼 Work & skills supports (SSA §1115 authority)
- “Engage or exempt” model: job search/training, education, or recovery supports.
- Automatic exemptions: medical frailty, caregiving, pregnancy/postpartum (12 months), students.
- Good‑cause protections; federal match for transport/childcare supports.
🏥 Primary care and value‑based payments (SSA §1902(a))
- Primary care floor at 100% of Medicare Part B rates; bonus for timely access.
- Reimburse integrated care teams: CHWs, behavioral health in primary care.
- Shared‑savings contracts tied to quality metrics and ER diversion.
💊 Pharmacy & PBM reform (SSA §1927)
- Ban spread pricing; mandate full pass‑through of rebates/discounts.
- State audit rights over PBM contracts, networks, and claims.
- 48‑hour approval or deem‑approved for generics/biosimilars when clinically appropriate.
🌾 Rural access & telehealth
- Global budgets for rural hospitals/clinics tied to access and quality.
- Telehealth parity (including audio‑only where appropriate) for primary, behavioral, specialty.
- Mobile clinic grants for dental, vision, and primary care.
🧠 Behavioral health integration
- Same‑day billing permitted for primary + behavioral at same site.
- Coverage for mobile crisis, stabilization, MAT, IOP, and peer support.
- No arbitrary visit caps; medical necessity governs.
📊 Transparency & public dashboards
- Monthly public KPIs: enrollment, wait times, ER use, maternal/behavioral outcomes, PMPM spend.
- Publish managed care and PBM contracts, rate methods, guarantees, penalties.
- Public complaint tracker with timestamps and resolution SLAs.
💡 Evaluation, sunset, and reinvestment
- Independent evaluation at 5 years on integrity, access, outcomes, and spend.
- Sunset unless benchmarks met or exceeded; continuation tied to results.
- ≥ 50% of verified savings reinvested in primary care, workforce, rural access.
Implementation path
- 0–90 days Draft 1115 waiver; stakeholder sessions with providers, beneficiaries, employers, counties.
- 90–180 days Submit to CMS; build dashboards; finalize PBM pass‑through contracts.
- Year 1 Launch pilots in one rural and one urban region; independent baseline study.
- Years 2–3 Scale statewide if access, quality, and budget targets are met.
Budget impact
- Expected savings from integrity measures, ER diversion, and PBM reforms.
- Budget neutrality for waivers; transparent annual reporting to Congress and states.
- Mandatory reinvestment of savings into primary care capacity, workforce supports, rural access.
Call to action: Align counsel and agencies on statutory amendments and waiver language; prepare data-sharing MOUs; stand up public dashboards to demonstrate quick wins on integrity and access.