DEPARTMENT OF HEALTH & HUMAN SERVICES 
Centers for Medicare & Medicaid 
Services 7500 Security Boulevard 
Mail Stop S2-26-12  
Baltimore, Maryland 21244-1850 
CMCS Informational Bulletin 
 
DATE:  November 7, 2023 
 
FROM:  Daniel Tsai, Deputy Administrator and Director 
 
SUBJECT:  Medicaid and CHIP Managed Care Monitoring and Oversight Tools 
 
 
The purpose of this Center for Medicaid and CHIP Services (CMCS) Informational Bulletin 
(CIB) is to provide additional tools for States and the Centers for Medicare & Medicaid Services 
(CMS) to improve the monitoring and oversight of managed care in Medicaid and the Childrens 
Health Insurance Program (CHIP). 
 
Introduction 
To improve monitoring and oversight of States Medicaid and CHIP programs, we have released 
two CIBs that included reporting templates and toolkits.  This CIB is the third in this series. 
On June 28, 2021, CMS released the first CIB1 that introduced a reporting template for the 
Managed Care Program Annual Report (MCPAR), announced the development of a web-based 
reporting portal for the collection of all required managed care reports, and announced release of 
two technical assistance toolkits for State use on behavioral health access and the Medicaid and 
CHIP managed care quality strategy.  In this guidance, CMS committed to developing additional 
tools for monitoring and oversight of managed care.   
 
On July 6, 2022, CMS published the second CIB2 that provided an update on the web-based 
reporting portal and introduced two additional reporting templates for the Medical Loss Ratio 
(MLR) Report and the Network Adequacy and Access Assurances Report (NAAAR).  
Additionally, this guidance announced release of a new technical assistance toolkit for States on 
managed long-term services and supports (MLTSS) and published initial recommended practices 
and strategies for ensuring timely and accurate payment to Indian health care providers. 
 
Today, CMS is releasing the third CIB that provides additional updates and reminders on the 
web-based reporting portal and the reporting requirements for managed care programs.  This 
guidance also provides an update on CMS process for review and approval of managed care 
contracts, rate certifications, and State directed payments, and announces the release of several 
new technical assistance toolkits. 
                                                      
1 https://www.medicaid.gov/federal-policy-guidance/downloads/cib06282021.pdf  
2 https://www.medicaid.gov/federal-policy-guidance/downloads/cib07062022.pdf   Page 2  CMCS Informational Bulletin 
 
 
Required Managed Care Reporting 
The managed care regulations require States to submit reports to CMS about their managed care 
programs on an annual or periodic basis, including: the MCPAR required in 42 CFR  438.66(e) 
for Medicaid only, the MLR Summary Report required in 42 CFR  438.74(a) and 457.1203(e) 
for Medicaid and CHIP respectively, and the NAAAR required in 42 CFR  438.207(d) and 
457.1230(b), respectively.  Specific information on each of these reports is available on 
Medicaid.gov.3  
 
CMS previously published Excel templates for each report.  However, CMS has since launched a 
web-based submission portal, known as the Medicaid Data Collection Tool for Managed Care 
Reporting (MDCT-MCR), which can now collect both MCPAR and MLR reports from States.  
For both reports, the MDCT-MCR collects the same information included in the Excel templates, 
creating a single submission process and repository for these State reporting requirements.  CMS 
expects to incorporate all required managed care reports into the MDCT-MCR system over time.  
The structured data captured by this system will allow CMS to generate and analyze State-
specific and nationwide data across all managed care programs and requirements.  CMS will use 
these data to identify areas that need improvement and target technical assistance to help States 
improve their managed care programs and comply with managed care statutory and regulatory 
requirements. 
 
Medical Loss Ratio (MLR) Summary Reporting in the MDCT-MCR 
Federal regulations at 42 CFR  438.74(a) and 457.1203(e) require that States submit annually 
(with their rate certification required in 42 CFR  438.7 for Medicaid) a summary description of 
the MLR report(s) received from the managed care organizations (MCOs), prepaid inpatient 
health plans (PIHPs), and prepaid ambulatory health plans (PAHPs) under contract with the 
State.  CMS released the Excel template for this reporting as part of the CIB published on July 6, 
2022.   
 
CMS is pleased to announce that the MLR Summary Report is now available for States to submit 
through the MDCT-MCR.  States that are ready to submit their MLR Summary Reports through 
the online portal can begin immediately.  MLR Summary Reports required as part of the rate 
certification submission for rating periods beginning on or after July 1, 2024, must be submitted 
through the MDCT-MCR.   
 
MDCT-MCR access is limited to State employees authorized by their State leadership.  CMS has 
been in contact with each States representative to the Managed Care Technical Advisory Group 
(MC-TAG) to explain the process to authorize and apply for access.  Each State must follow the 
instructions to gain access to the system.4  While States can still use the Excel template internally 
to gather the necessary information, States must enter and submit the report through the MDCT-
MCR by the deadline outlined above. 
 
                                                      
3 https://www.medicaid.gov/medicaid/managed-care/guidance/medicaid-and-chip-managed-care-
reporting/index.html  
4 Instructions for gaining access to MCDT-MCR are located here: https://www.medicaid.gov/resources-for-
states/medicaid-and-chip-program-portal/medicaid-data-collection-tool-mdct-portal/index.html#MCR  
 
  Page 3  CMCS Informational Bulletin 
 
Managed Care Reporting Reminders 
CMS would also like to remind States of the submission requirements for the MCPAR and 
NAAAR.   
 
Managed Care Annual Program Report (MCPAR) 
Federal regulations at 42 CFR  438.66(e) require States to submit a MCPAR.  Each State must 
submit to CMS, no later than 180 days after each contract year, a report on each Medicaid 
managed care program administered by the State.  The report is collected through the MDCT-
MCR.  The requirement to submit the annual report was triggered by the CIB published on June 
28, 2021, and the deadline for State submission is dependent upon the contract year of each 
managed care program.  The due dates for the next round of reports are listed below and reports 
are required each year thereafter. 
 
Contract Year of the  Contract Period   Next Report Due 
Managed Care Program  of Next Report 
July through June  7/1/2022  6/30/2023  December 27, 2023 
September through August  9/1/2022  8/31/2023  February 27, 2024 
October through September  10/1/2022  9/30/2023  March 28, 2024 
January through December  1/1/2023  12/31/2023  June 28, 2024 
February through January  2/1/2023  1/31/2024  July 29, 2024 
April through March  4/1/2023  3/31/2024  September 27, 2024 
 
Network Adequacy and Access Assurances Report (NAAAR) 
Federal regulations at 42 CFR  438.207(d) and 457.1230(b) require that States must: 
  Submit an assurance of compliance to CMS that each MCO, PIHP, and PAHP meets the 
States requirement for availability of services; and 
  Include documentation of an analysis that supports the assurance of the adequacy of the 
network for each contracted MCO, PIHP, or PAHP related to its provider network. 
 
The information is required to be submitted: 
  At the time the State enters into a contract with each MCO, PIHP, or PAHP; 
  On an annual basis; and 
  Any time there is a significant change in the operations that would affect the adequacy of 
capacity and services of an MCO, PIHP, or PAHP. 
Note: CMS recommends that the report be submitted at the same time a State submits the 
associated managed care contract to CMS for review and approval, including a new contract, 
a renewal, or an amendment.   
 
The CIB published on July 6, 2022, announced the release of the Excel template5 for the 
NAAAR.  In the future, this report will be collected through the MDCT-MCR, though this 
reporting functionality is not yet available.  CMS will notify States when the web-based NAAAR 
form is available.  Until that time, States are required to submit the Excel template of the report 
to MCGDMCOActions@cms.hhs.gov.   
                                                      
5 https://www.medicaid.gov/medicaid/managed-care/guidance/medicaid-and-chip-managed-care-
reporting/index.html  
 
  Page 4  CMCS Informational Bulletin 
 
 
Comprehensive information about all managed care reporting requirements is available on 
Medicaid.gov.6   
 
CMS Review of Managed Care Contracts, Rate Certifications, and State Directed 
Payments 
 
Federal regulations at 42 CFR  438.3, 438.4, and 438.7 require CMS to review and approve 
States Medicaid managed care contracts and rate certifications. Regulations at 42 CFR  
457.1201(a) require CMS to review separate CHIP managed care contracts.  In accordance with 
42 CFR  438.6(c), most State directed payments in Medicaid also require prior CMS approval 
through a preprint form.  Medicaid and CHIP capitation rates must be documented in executed 
MCO, PIHP, and PAHP contracts as required at 42 CFR  438.3(c)(1)(ii) and 457.1201(c), and 
any changes to the capitation rates must be documented in executed contract amendments.  State 
directed payments must also be documented in executed Medicaid managed care contracts and 
incorporated into Medicaid rate certifications.   
 
In a CIB published on November 8, 2019,7 CMS outlined process improvements to CMS review 
of managed care contracts and rate certifications and included a tip sheet for a complete contract 
action submission.  CMS has published several pieces of guidance on State directed payments, 
including SMD# 21-001 on January 8, 2021, which released a revised preprint template.89  On 
November 23, 2021, CMS published a CIB outlining revisions to the submission process for 
managed care contracts, rate certifications, and State directed payment preprints.10   
 
CMS continues to experience delays in State submission of complete Medicaid managed care 
contract actions, rate certifications, and State directed payment preprints; these delays prevent 
timely CMS review of these actions.  Therefore, CMS is publishing this guidance on the 
components of a complete submission.  CMS will not begin formal review of contracts, rate 
certifications, and State directed payment preprints until we receive a complete submission of the 
contracts, rate certifications, and State directed payment preprints. Below we outline the process 
for each of these. 
 
Managed Care Plan Contracts 
A complete managed care plan11 contract action submission includes many components, 
including contract actions signed and dated by all parties which include all pages, appendices, 
and attachments, as well as any documents that are incorporated into the contract by reference,12 
and additional required documentation, when applicable, such as rate certifications, MLR 
                                                      
6 https://www.medicaid.gov/medicaid/managed-care/guidance/medicaid-and-chip-managed-care-
reporting/index.html  
7 https://www.medicaid.gov/federal-policy-guidance/downloads/cib110819.pdf  
8 https://www.medicaid.gov/Federal-Policy-Guidance/Downloads/smd21001.pdf  
9 https://www.medicaid.gov/sites/default/files/2022-12/sdp-4386c-preprint-template-12192022.pdf  
10 https://www.medicaid.gov/federal-policy-guidance/downloads/cib112321.pdf  
11 The term managed care plan refers to MCOs, PIHPs, PAHPs and PCCM entities when utilized. 
12 States may choose to utilize additional documentation outside of managed care plan contracts to apply standards 
and provide guidance on what the contract requires; however, any new requirements or those that make changes to 
payment, or the work performed under the contract should be included in the managed care plan contract.  
 
  Page 5  CMCS Informational Bulletin 
 
Summary Reports, etc.  See Appendix 1 for details on the components of a complete managed 
care plan contract submission.  This appendix has been updated from the addendum included in 
the CIB published on November 8, 2019, to provide additional clarity to States. 
 
Historically, CMS has begun its review of managed care plan contracts once it is received, even 
in cases where components of the managed care plan contract were missing or other key 
documents such as rate certifications were absent.  This approach has led to inefficiencies in our 
review process and resulted in increasingly long review times.  For example, in some cases, 
CMS has asked States questions regarding an incomplete contract submission that were then 
subsequently answered in missing contractual documentation; these questions could have been 
avoided if the States submitted all relevant documentation concurrently. We are concerned about 
the unnecessary administrative burden that this causes for both States and CMS.  We are also 
concerned that these inefficiencies appear to be growing.  In 2020, CMS waited an average of 79 
days between receiving States initial submissions and complete contract packages.  By 2023, 
that number had increased substantially to 232 days.   
 
We believe it is vital for States to submit complete managed care plan contracts in a timely and 
efficient manner to CMS for our review and approval of these contracts as required in 42 CFR  
438.3 and 457.1201(a), and consistent with authority in section 1902(a)(4) of the Social Security 
Act to establish methods for proper and efficient operation in Medicaid and section 2101(a) of 
the Act for establishing efficient and effective health assistance in CHIP.  Therefore, CMS is 
now outlining the minimum documentation standards that must be met within a managed care 
plan contract submission before CMS will begin review.  CMS is implementing this new 
requirement in two phases, to allow States time to make internal operational changes, if 
necessary, to comply with these documentation standards.  Phase 1 will begin for any managed 
care plan contract effective on or after July 1, 2024, and Phase 2 will begin for managed care 
contracts effective on or after July 1, 2025.  See Appendix 2 for further details on this approach. 
 
With the recent reorganization in CMCS to create the Managed Care Group, the current mailbox 
that States are expected to submit managed care contracts to has changed.  States should submit 
all managed care plan contracts to CMCS at: MCGDMCOActions@cms.hhs.gov.  Additionally, 
States should continue to submit all State contract actions with Medicaid managed care plans, 
including associated rate certifications, to the MMCratesetting@cms.hhs.gov mailbox to ensure 
timely review of Medicaid managed care rate development.   
 
Medicaid Rate Certifications 
If a contract submission is for a risk-based managed care plan contract and includes a rate 
certification, the rate certification must meet certain documentation standards to be considered 
complete before CMS will begin review of the rate certification.  The rate certification must be 
signed by an actuary meeting the qualifications in 42 CFR  438.2 and developed in accordance 
with the rate development standards and documentation expectations outlined in the Medicaid 
Managed Care Rate Development Guide.13  As noted in this guide, the rate certification must 
include both the letter or attestation from the actuary that specifically certifies that the capitation 
rates or rate ranges are actuarially sound and meets applicable Federal requirements, and all 
supporting documentation that relates to the letter or attestation, including the actuarial report, 
                                                      
13 https://www.medicaid.gov/medicaid/managed-care/guidance/rate-review-and-rate-guides/index.html  
 
  Page 6  CMCS Informational Bulletin 
 
other reports, letters, memorandums, other communications, and other workbooks or data.   
 
Medicaid State Directed Payments 
For those State directed payments that require written prior approval, CMS must receive a 
complete preprint before CMS will begin review.  A complete State directed payment preprint 
submission requires a State directed payments preprint form14 as well as the preprint addendum 
tables15 in an Excel workbook, as necessary.  State directed payments granted prior written 
approval on or after February 1, 2023, pursuant to 42 CFR  438.6(c), are published on 
Medicaid.gov.16  As such, all preprint submissions must comply with Section 508 of the 
Rehabilitation Act (Section 508) and the preprint has been made compliant to enable timely 
posting. 
 
The preprint must be completed in full, and all information must be provided only in the fillable 
sections of the preprint and the addendum tables.  No additions or markings, including 
comments, are permitted in order to maintain Section 508 compliance.  When possible, the State 
should use the addendum tables, rather than provide separate supporting documentation.  The 
preprint, addendum tables, and any other supporting documents must be submitted as separate 
files, without merging or reformatting. 
 
For those State directed payments that require written prior approval, CMS strongly recommends 
that States submit preprints to CMS at least 90 calendar days before the start of the applicable 
rating period.  To request technical assistance or submit a State directed payment preprint for 
review, States should use the following mailbox: StateDirectedPayment@cms.hhs.gov. 
 
Additionally, for each State directed payment, the risk-based managed care plan contracts must 
include a description of providers entitled to the payment, how it is authorized, how the State is 
directing the plans to pay the providers, and any reporting requirements the managed care plans 
must meet to show they have met those requirements.  Requirements for each payment should be 
sufficiently detailed in the contracts to enable the plans to consistently operationalize each 
payment arrangement in alignment with CMS approval of the State directed payment preprint(s). 
 
Technical Assistance Toolkits for States17 
In the CIB published June 28, 2021, CMS committed to developing a series of technical 
assistance toolkits to assist States in complying with various managed care standards and 
regulations and to help improve State monitoring and oversight of their managed care programs.  
Today, CMS is releasing several new toolkits, described below. 
 
                                                      
14 https://www.medicaid.gov/sites/default/files/2022-12/sdp-4386c-preprint-template-12192022.pdf 
15 The preprint addendum is an Excel document, entitled Section 438.6(c) Preprint Addendum Tables which can 
be downloaded from here.  
16 https://www.medicaid.gov/medicaid/managed-care/guidance/state-directed-payments/approved-state-directed-
payment-preprints  
17 Most toolkits can be found at the CMS Medicaid and CHIP Managed Care Monitoring and Oversight Initiative 
webpage: https://www.medicaid.gov/medicaid/managed-care/guidance/medicaid-and-chip-managed-care-
monitoring-and-oversight-initiative/index.html  
 
  Page 7  CMCS Informational Bulletin 
 
Medicaid Managed Care Plan Transitions 
Today, CMS is releasing a toolkit entitled, Medicaid Managed Care Plan Transitions: A Toolkit 
for States on Promoting Continuity of Care When Plans Enter, Leave, or Merge or are 
Acquired.  As the MCOs, PIHPs, and PAHPs operating in States Medicaid managed care 
programs change, States and plans must ensure there are no disruptions in enrollees access to 
care.  States can mitigate the risk of disruption through planning, implementation, and 
monitoring of plan transitions, as well as developing associated managed care contractual 
requirements.  This toolkit provides steps that States can take during each phase of a transition to 
support successful movement of enrollees from one plan to another, clear communications with 
enrollees about the impact of a transition and their rights and options, and facilitation of 
continuity of care with established and new providers.  The toolkit is available on 
Medicaid.gov.18  
 
Tribal Protections in Medicaid and CHIP Managed Care 
Today, CMS is releasing a toolkit entitled, Tribal Protections in Medicaid and CHIP Managed 
Care Oversight.  To assist states in complying with the statutory and regulatory Indian managed 
care protections, CMS met with States, Tribes, Indian health care providers (IHCPs), and 
managed care plans to identify and resolve implementation and compliance issues on a State-by-
State basis.  To address implementation of the Indian managed care protections from a national 
perspective, the National Indian Health Board (NIHB) and CMS convened a Tribal Medicaid 
Managed Care Virtual Roundtable in May 2021.  The Roundtable panelists included Tribal 
health directors, State Medicaid staff, and managed care plan staff who gathered to discuss 
strategies and identify recommended practices and resources that could be used to aid States and 
managed care plans in implementing the statutory and regulatory Indian Medicaid managed care 
protections.  In July 2022, NIHB produced a Roundtable Report that memorialized the 
recommended practices and strategies for addressing Medicaid and CHIP managed care issues in 
Indian Country.19  This toolkit builds upon the Roundtable Report by providing more detail on 
these recommendations.  The toolkit provides an overview of the Indian health delivery system, 
statutory and regulatory protections, and recommended implementation practices.  The toolkit is 
available on Medicaid.gov.20    
 
Validating Medicaid Managed Care Encounter Data 
In August 2019, CMS published a toolkit, entitled Validating Medicaid Managed Care 
Encounter Data, that provides practical information States can use to validate and improve the 
Medicaid encounter data they receive from their managed care plans.  The toolkit describes 
activities that all States should perform to ensure high quality data, and includes examples of 
current State practices, checklists to assist State staff who conduct validation, and resources that 
provide helpful tips and tools.  We have updated this toolkit to incorporate guidance about the 
periodic audit process for encounter data, as required at 42 CFR  438.602(e).  This toolkit 
provides techniques to help states ensure robust audits of their encounter data validation 
processes to assess the accuracy, truthfulness, and completeness of their encounter data and the 
sufficiency of their validation processes.  The toolkit is available on Medicaid.gov.21  
                                                      
18 https://www.medicaid.gov/sites/default/files/2023-10/mmcp-transtons-tolkit.pdf  
19 https://www.nihb.org/docs/phrc-uploads/08152022/medicaid-managed-care-report_final_08102022.pdf  
20 https://www.medicaid.gov/sites/default/files/2023-10/trbl-protcns-medcd-chip-mngd-care-ovrsght-tolkt.pdf 
21 https://www.medicaid.gov/sites/default/files/2023-10/mmce-data-valdtn-tolkit.pdf 
 
  Page 8  CMCS Informational Bulletin 
 
 
Program Integrity  
On November 1, 2023, CMS released four program integrity toolkits to provide States and 
managed care plans with guidance on optimizing program accountability and transparency.  The 
topics for these toolkits were identified as the most pressing challenges for States based on 42 
CFR 438 Subpart H (adopted in CHIP via cross-reference at 42 CFR  457.1285) regulatory 
requirements, State technical assistance requests raised in the Fraud, Waste, and Abuse 
Technical Advisory Group, and State educational requests in Medicaid Integrity Institute (MII) 
trainings.22  These program integrity toolkits provide information and examples regarding 
oversight practices that States should consider to ensure that effective program integrity 
measures are in place.  The program integrity toolkits are described below. 
 
Compliance Program Requirements 
The Compliance Program Requirements toolkit discusses the compliance program requirements 
that States must follow when entering into contracts with managed care plans.  Specifically, 
CMS regulations at 42 CFR  438.608(a)(1) require that States, through contracts with managed 
care plans, must require managed care plans to implement and maintain arrangements or 
procedures designed to detect and prevent fraud, waste, and abuse.  These arrangements or 
procedures must include a compliance program that meets several minimum elements.  The 
toolkit is available on Medicaid.gov.23   
 
Prompt Referrals of Potential Fraud, Waste, or Abuse 
The Prompt Referrals of Potential Fraud, Waste, or Abuse toolkit outlines the requirements of 
managed care plans to promptly report and establish clear timelines for referrals of potential 
fraud, waste, or abuse to the State Medicaid Program Integrity (PI) Unit or Medicaid Fraud 
Control Unit (MFCU), as required in 42 CFR  438.608(a)(7).  When referring potential fraud, 
waste, or abuse, States have the discretion to stipulate the ways managed care plans can report 
potential fraud.  The toolkit is available on Medicaid.gov.24  
 
Treatment of Overpayments and Recoveries  
The Treatment of Overpayments and Recoveries toolkit discusses how recoveries of network 
provider overpayments may be treated under requirements found in 42 CFR  438.608(d) and 
(a)(2).  These regulations provide States with flexibility on how to handle recoveries made by 
managed care plans to create incentives for managed care plans to proactively oversee network 
provider billing practices and identify fraud, waste, and abuse.  The toolkit is available on 
Medicaid.gov. 25 
 
Payment Suspensions Based on Credible Allegations of Fraud 
This Payment Suspensions Based on Credible Allegations of Fraud toolkit discusses managed 
care-related payment suspensions and the procedures in place to suspend payment when there is 
                                                      
22 Learn more about MII trainings at: https://www.cms.gov/medicaid-integrity-institute.  
23 https://www.cms.gov/files/document/managed-care-compliance.pdf  
24 https://www.cms.gov/files/document/managed-care-fraud-referral.pdf  
25 https://www.cms.gov/files/document/managed-care-overpayment-recoveries.pdf 
 
 
 
  Page 9  CMCS Informational Bulletin 
 
a credible allegation of fraud, consistent with requirements found in 42 CFR  438.608(a)(8).  
States have an important oversight responsibility when implementing payment suspensions for 
network providers, and CMS encourages States and managed care plans to collaborate 
throughout this process.  The toolkit is available on Medicaid.gov.26  
 
Closing  
CMS is committed to strengthening the monitoring and oversight of Medicaid and CHIP 
managed care programs and looks forward to continuing to collaborate with States on the 
implementation of these tools.  CMS anticipates issuing additional tools in the future to improve 
monitoring and oversight activities in Medicaid and CHIP managed care.  If you have any 
questions or need additional information, please contact ManagedCareTA@cms.hhs.gov. 
                                                      
26 https://www.cms.gov/files/document/managed-care-payment-suspensions.pdf 
 
  Page 10  CMCS Informational Bulletin 
 
Appendix 1: Components of a Complete Managed Care Plan Contract Submission 
 
Before CMS can approve Medicaid managed care plan contracts in accordance with 42 CFR  
438.3(a) and finalize our review of CHIP managed care contracts in accordance with  
457.1201(a), all contract submission packages must include:  
 
1.  Contract action(s) signed and dated by all parties which include all pages, appendices, 
and attachments, as well as any documents that are incorporated into the contract by 
reference, and  
 
2.  The following additional documentation, as described in the chart below.   
 
When the Contract Action:  Additional  Regulatory Reference 
Documentation Required 
Implements or amends Medicaid  Rate certification and all  Medicaid:  438.7 
capitation rates27   supporting documentation, 
when required28 
Implements capitation rates for the  MLR Summary Reports29  Medicaid:  438.74(a)  
states annual rating period  CHIP:  457.1203(e) 
Provides any services to MCO enrollees  Parity analysis in mental  Medicaid:  
using a delivery system other than the  health and substance use  438.3(n)(2) and 438.920  
MCO and there is (1) a change in  disorder (SUD) benefits  CHIP:  457.496(f) 
benefits provided by the MCO, PIHP,  and 457.1201(l) 
PAHP, or FFS is occurring; or (2) the 
State is contracting with a new MCO(s) 
Implements in Medicaid (1) a new  Readiness review results  Medicaid:  
managed care program; (2) a new  438.66(d)(2)(iii) 
managed care plan not previously 
contracted with the State; or (3) the 
provision of covered benefits to new 
eligibility groups. 
 
Additionally, CMS recommends that the NAAAR be submitted when a State submits the 
associated managed care plan contract to CMS.  See the section entitled, Required Managed Care 
Reporting, for further details.   
   
                                                      
27 The only exception is when States are permitted to either use the rate range option under 42 CFR  438.4(c)(1) 
or use the de minimis rate adjustment under 438.7(c)(3), but States are not permitted to use both mechanisms in 
combination.  Note that CMS documentation expectations for these State flexibilities are outlined in Section I.1 of 
the Medicaid Managed Care Rate Development Guide. 
28 Rate development standards and CMSs documentation expectations for rate certifications are outlined in the 
Medicaid Managed Care Rate Development Guide.  
29 As outlined in the section entitled, Medical Loss Ratio (MLR) Summary Reporting in the MDCT-MCR, States 
will be expected to submit these reports within MDCT-MCR by the outlined deadline.  As such, a State should 
confirm that it completed this respective submission in MDCT-MCR when a State submits the associated managed 
care plan contract action via email to the respective mailboxes outlined above. 
 
 
  Page 11  CMCS Informational Bulletin 
 
Appendix 2: CMS Process for Reviewing Managed Care Plan Contracts 
 
As outlined in the chart below, CMS will not begin review of managed care plan contracts 
submitted by States until minimum documentation standards are met as outlined  
in the below chart.  These changes to CMS review process will occur in two phases to allow 
States time to make internal operational changes.  CMS strongly encourages States to submit 
contract actions consistent with all applicable documentation standards before the effective date 
of the managed care plan contract to facilitate timely and efficient review by CMS.   
 
Minimum Documentation Standards Necessary for CMS to Begin Review of Managed Care Plan 
Contracts 
 
Phase 1: Contract actions with an effective  Phase 2: Contract actions with an effective date on 
date on or after 7/1/2024  or after 7/1/2025 
1.  Base contract(s) or contract  1.  Executed base contract(s) or contract 
amendment(s) (during Phase 1 these  amendment(s), signed and dated by all parties; 
can be unsigned, but should include  2.  All appendices, attachments, and any 
final language);  documents incorporated by reference into the 
2.  All appendices, attachments and any  contract; 
documents incorporated by reference  3.  Rate certification, if applicable 
into the contract; and   
3.  Rate certification, if applicable  And, when applicable: 
  4.  MLR Summary Report; 
  5.  Parity analysis in mental health and SUD 
CMS also recommends that States submit a  benefits;  
complete contract inclusive of prior  6.  Readiness review results; and 
amendments highlighting all current  7.  Submission of associated Medicaid/CHIP 
changes.  This additional documentation  authority (e.g., State plan amendment, waiver 
will likely result in fewer CMS questions  under sections 1915(b) or 1915(c) of the Social 
and any submission that includes this detail  Security Act, State directed payment preprint) 
will be prioritized for more expeditious  for applicable contractual requirements.30 
review.   
  CMS also recommends that States submit a 
complete contract inclusive of prior amendments 
highlighting all current changes.  This additional 
documentation will likely result in fewer CMS 
questions and any submission that includes this 
detail will be prioritized for more expeditious 
review. 
 
                                                      
30 As a reminder for States, CMS will not approve managed care plan contracts until all necessary Medicaid 
authority is approved that is associated with the contractual requirements.  For example, if a contract action includes 
a programmatic change to require a managed care plan to deliver a new Medicaid benefit to Medicaid managed care 
enrollees, the associated Medicaid State plan or waiver authority must be approved before CMS can consider the 
managed care plan contract action for approval.  As such, we believe that these necessary Medicaid authorities 
should at least be submitted to CMS before CMS will begin review of the associated managed care plan contracts.