*This blog post was authored by Ash Bliss, Legal Intern, Alexander Cross, Legal Intern, and Daniel Young, Policy Analyst.
Medicaid Advisory Committees (MAC) and Beneficiary Advisory Councils (BAC) are going live on July 9… Or they should be.
Last week, Republicans in Congress made unprecedented cuts to Medicaid that will lead to anticipated reductions in services, the imposition of work requirements, and the expectation that millions of beneficiaries will lose coverage. Now more than ever, Medicaid beneficiaries need a voice in the future of Medicaid. The implementation of MACs and BACs is good policy that will strengthen financially-stressed state Medicaid programs by centering beneficiary experience and lifting up beneficiary voices as states grapple with the changes that are coming to Medicaid.
The Medicaid Access Rule, finalized by CMS in May 2024, mandated the implementation of MAC-BAC. The rule requires states to establish new committees or strengthen existing advisory groups by July 9, 2025. These committees aim to improve Medicaid through increasing beneficiary engagement and feedback in policy and program decisions. NHeLP has presented on the structure and implementation challenges of establishing these committees and written recommendations and best practices to help ensure meaningful stakeholder engagement.
NHeLP works with partners around the country to share resources and develop model examples for other states to follow to ensure that the MAC-BACs achieve their intended purpose. One area where advocates and beneficiaries should look to get involved is in the development of their state’s MAC-BAC governance documents. Bylaws are essentially the foundation upon which the MAC-BAC house is built. A strong foundation will lead to an effective MAC-BAC. A shaky or defective foundation will lead to collapse. Among other objectives, strong bylaws should explain how MAC-BAC meetings are run and how agenda items should be decided upon. Bylaws should stress the importance of the beneficiaries as the ones responsible for bringing policy issues and suggestions for improving Medicaid to the state; and that the responsibility of the state is to be responsive to those suggestions. Bylaws should also describe all of the support that states will provide beneficiary members to help them successfully participate in MAC-BAC meetings.
As the MAC-BAC implementation date is upon us, NHelP is tracking where states are in their progress towards making these MACs and BACs a reality. Clearly, states have a great deal of work yet to do. In fact, the great diversity between all fifty states, the District of Columbia, and Puerto Rico is reflected in their equally-diverse approaches to systemization, recruitment, engagement, and transparency as they approach the deadline to implement the new regulations.
Of all the states, fewer than half (twenty-four) have established, or are presently recruiting for, both a MAC and a BAC. Some states’ BAC has already convened, but recruitment is still ongoing for most––the week of the implementation deadline. Thirteen states have a MAC, but no BAC; it is worth noting that many of these states have merely renamed their Medical Care Advisory Committee (MCAC), an entity rendered obsolete by the Final Access Rule, without substantial compliance beyond that fact. Two states have published information on their BAC, but have no apparent MAC implementation in progress. Eight states have made no changes to their preexisting MCAC, nor have they published plans to make other changes in compliance with the new regulations. Four states seem to have no functioning MCAC, MAC, or BAC in operation, with no apparent plans for them either.
National Progress Towards MAC-BAC Implementation (Number of States), July 3, 2025:
- 24 MAC-BAC implemented or in-progress
- 13 Only MAC implemented or in-progress
- 2 Only BAC implemented or in-progress
- 8 MCAC unchanged
- 4 NONE
Many states have done little to even make their progress known to the public. We encourage states to keep the public up-to-date on the implementation and operation of their MAC-BAC as a best practice, but advocates can also track their compliance based on transparency regulations. The Medicaid Access Rule actually requires states to publish a fair number of documents directly to their websites as their MAC and BAC coalesce. In its Introduction to the Access Rule, CMS specifically called for greater transparency than the former MCAC regulations, and stipulated that states must post meeting times, dates, membership lists, and minutes, as well as an annual report of MAC-BAC activities in order to build greater accountability and trust with the public.
Of the states which regularly update the public on their work, Utah and Maine––along with others like South Dakota and Rhode Island––exercise a high level of public communication in their progress implementing their MAC-BAC.. Utah and Maine each have separate, functional websites for both the MAC and BAC, incorporating many of the Access Rule’s new directions. Both states’ websites host bylaws for each committee, along with minutes and materials archived from past meetings.
In Utah, both the MAC and BAC meetings are open to the public, and each website has published meeting schedules with attached materials, contact information, and registration links to join remotely. In contrast, while the Maine MAC meetings are ostensibly open to the public, one must email the MAC Chair to be granted remote access, which is a barrier. Maine’s BAC meetings are also not typically open to the public, though the BAC bylaws do provide a notice process for alerting the public to open BAC meetings, suggesting that at least some will be.
Each state has also generally incorporated the Medicaid Access Rule’s requirements into the materials available on their MAC and BAC websites, respectively. Still, even as leaders in implementation, both states fall short of achieving full compliance with the regulations. Other states like Wyoming and Massachusetts, have made very few public-facing materials available.
Recommendations of what state advocates can do check their state’s progress:
- Check your state’s Medicaid website for updates on MAC-BAC implementation.
- Is your state actively accepting applications for the MAC and BAC?
- Are you currently or do you have lived experience as a Medicaid beneficiary? Apply to serve on the MAC or BAC.
- If you do not meet the criteria for membership, publicize the application and application process to your networks.
- Attend a MAC meeting if your state has already scheduled public MAC meetings.
- If your state has not started MAC-BAC implementation, attend your state’s next MCAC meeting and inquire about the state’s plans for MAC-BAC implementation.
There will be many changes coming to Medicaid with the potential to harm beneficiaries. It is crucial that beneficiaries and advocates work with their state Medicaid agencies to navigate the forthcoming changes to and budget restrictions in their Medicaid programs. With careful planning and thoughtful implementation, the MAC-BACs offer a great platform for beneficiaries, advocates, and state agency staff to work together to center beneficiary voices and experiences to identify harms and develop policies that mitigate their effects on low-income communities. NHeLP will continue tracking state progress and can provide technical assistance to advocates who hope to have an impact making their state’s MAC-BACs functional and effective.
Resources
- NHeLP: Medicaid Advisory Committees: Best Practices for Effective Stakeholder Engagement
- NC Justice Center: How to Plan and Run an Accessible and Inclusive Meeting
