Delivery System Reform

The National Health Law Program (NHeLP) Delivery Systems team focuses on the policy, payment, and legal structures that dictate how Medicaid operates, including which providers participate, how prior authorizations are handled, and other important specifics about how people enrolled in Medicaid access their benefits on a day-to-day basis. NHeLP has long been an influential advocacy and litigation leader that pushes for transparency, accountability, and due process to protect access to care for low-income people enrolled in Medicaid. 

Over time, managed care models have replaced fee-for-service as the dominant Medicaid delivery system. Currently, more than three out of four people with Medicaid receive their services through a contracted managed care organization. 

Different delivery systems present different obstacles for access to care. In managed care plans, enrollees may struggle to find new providers due to error-filled provider directories and narrow plan networks. They face administrative hurdles like lengthy prior authorization processes or wrongful denials that often cause delays or foregone care. NHeLP advocates for active accountability measures, effective quality metrics, enrollee protections, and other policy solutions on a state and federal level to work toward a system that prioritizes people over plan profits.

Access to care problems stemming from Medicaid managed care and other delivery systems disproportionately affect underserved communities, including Black, Indigenous, and people of color, people with disabilities, older adults, and LGBTQI+ individuals. We see this in clinical assessment tools that reproduce the biases embedded in historical data used to develop them. It shows up when provider networks fail to accommodate the needs of people with disabilities and people with Limited English Proficiency. Our advocacy persistently demands delivery systems that effectively and transparently prioritize health equity as a core program goal.

Finally, as states explore new, alternative methods of delivering and paying for Medicaid services, our team works to make them equitable, transparent, and effective for low-income and underserved communities.


Major Types of Delivery Systems

Managed care: Under managed care, state Medicaid agencies contract with private companies to coordinate health care delivery for their residents. States typically pay these companies a fixed amount each month for each covered enrollee, regardless of how many services that enrollee actually uses, and allow plans to limit their provider networks.

Fee-for-service: In Fee-for-Service (FFS) systems, states contract with individual providers and pay them directly for the services or items they provide. This means that when a Medicaid member receives a service, such as a doctor’s visit, the doctor charges Medicaid an amount based on the state’s fee schedule.

Alternative Payment Models: Alternative payment models (APMs) are payment approaches that reward providers for delivering high-quality, cost-efficient care. APMs can apply to a specific clinical condition, a care episode, or a population. States experiment with payment approaches that differ from the above approaches, such as linking payment to specific quality outcomes or paying a fixed amount for a whole episode of care, like delivering a baby, as opposed to each individual service. These approaches can exist within FFS or managed care delivery systems.


 

Delivery Systems Priorities and Resources

Our Delivery Systems team works with staff across the National Health Law Program to advance more expansive access to Medicaid and to timely, high quality Medicaid services. The team priorities center on Network Adequacy, Due Process, Prior Authorization, Stakeholder Engagement, and Health Equity. Follow the links below to learn more.

Network Adequacy

States set standards that Medicaid health plans must meet to ensure enrollees can find available health care providers in a timely fashion.

Due Process

NHeLP’s due process litigation and policy advocacy has helped ensure Medicaid enrollee rights are not limited by the use of managed care and that Medicaid coverage is not denied or ended without appropriate notice and access to a hearing.

Prior Authorization

Health plans sometimes require pre-approval of  a service, treatment, prescription, or equipment to make sure it is medically necessary, safe, and cost-effective. This can create barriers to care.

Stakeholder Engagement

Medicaid law establishes various  processes to identify, analyze, and communicate with stakeholders to help inform and shape federal and state Medicaid services and policies.


Intersection of Federal Policy and Delivery Systems

Our Delivery Systems team advocates for Medicaid delivery system models that prioritize people over plan profits. On the federal level, NHeLP is a longstanding influential advocacy and litigation leader that pushes for transparency, accountability, and due process to protect access to care for low-income people enrolled in Medicaid. 

In addition to federal advocacy, NHeLP also works on policy in California. For more information about our California policy work, please visit our California Delivery System Reform page.

Featured Delivery System Reform Resources

Learn more about Due Process Litigation at NHeLP

Due process enforcement is an important aspect of Delivery System Reform advocacy, and is a common element in many of our cases because too often Medicaid enrollees’ coverage and services are threatened without the required processes that protect their access to critical services.

NHeLP’s due process litigation has been an important part of ensuring Medicaid enrollee rights are not impacted by the use of managed care and that Medicaid coverage is not denied or ended without appropriate notice and access to a hearing. NHeLP’s due process theories and litigation on ascertainability and accountability have been the building blocks for a variety of advocacy, including algorithmic fairness. Through its due process litigation, NHeLP has protected critical coverage and services and maintained foundational safety net requirements for services for which courts have long recognized people have a “brutal need.”

Learn more about our Due Process cases by clicking the button below, and find out more about all of our cases on the Litigation & Enforcement page.

Delivery System Reform Blogs

Meet the Delivery System Reform Team

David Machledt
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David Machledt

Senior Policy Analyst

David Machledt is a Senior Policy Analyst in the National Health Law Program’s Washington, D.C. offices. His work at…

Abigail Coursolle
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Abigail Coursolle

Senior Attorney

Abigail (Abbi) Coursolle is a Senior Attorney in the National Health Law Program’s Los Angeles offices. Abbi provides technical…

Daniel Young
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Daniel Young

Policy Analyst

Area(s) of expertise: Medicaid Managed Care quality, Maternal and Child Health, Health Care Facility AccesibilityDaniel Young is a Policy…

Wayne Turner
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Wayne Turner

Senior Attorney

Area(s) of Expertise: Prescription drugs, Medicaid managed care, eligibility using Modified Adjusted Gross Income, nondiscrimination protections and enforcement.Wayne Turner…

Sarah Somers
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Sarah Somers

Legal Director

Sarah Somers is the Legal Director at the National Health Law Program. In this role, Sarah leads NHeLP’s legal…

Elizabeth Edwards
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Elizabeth Edwards

Senior Attorney

Elizabeth Edwards is a Senior Attorney in the National Health Law Program’s North Carolina offices. In addition to working…

Christina Piecora
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Christina Piecora

Senior Policy Analyst

Before joining the National Health Law Program as our new Senior Policy Analyst, Christina worked as a consultant helping…

Brit Vanneman
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Brit Vanneman

Staff Attorney

Brit Vanneman, J.D., is a Staff Attorney for the National Health Law Program (NHeLP), where she supports two of…