NHeLP Comments to PERM Regulations

Executive Summary

In comments to the U.S. Department of Health and Human Services, NHeLP Director of Health Policy Leonardo Cuello recommends that HHS should make the Payment Error Rate Measurement regulations consistent with the recently released Medicaid managed care regulations and use the Payment Error Rate Measurement process as a tool to promote compliance with the new managed care requirements. NHeLP also recommends that HHS apply PERM criteria to managed care plan payments to providers, instead of only applying PERM to state capitation payments to managed care plans.

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