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Comparative Rate Analysis

Comparative Rate Analysis

2026 Access Rule Report Narrative

Summary:  This narrative description is intended to supplement the accompanying Excel‑based analysis prepared to meet the Medicaid Access Rule requirements for both the Comparative Payment Rate Analysis and the Payment Rate Disclosure components for CY2025 (due July 1, 2026). The Excel file is organized into four tabs—Primary Care, OB/GYN, MH/SUD, and HCBS Payment Disclosure—to align with federal reporting expectations and to allow reviewers to easily locate the relevant data for each service category. This narrative is provided to explain the methodology and purpose of the required components.

Comparative Payment Rate Analysis

The comparative payment rate analysis linked below was prepared in accordance with 42 CFR § 447.203(b)(2) and (3). The analysis compares Michigan Medicaid fee-for-service (FFS) payment rates for primary care, obstetrical and gynecological (OBGYN) services, and outpatient mental health and substance use disorder evaluation and management (E/M) services identified by CMS to corresponding Medicare non-facility payment rates.

The report is organized at the CPT/HCPCS code level using the CMS-provided Comparative Payment Rate Analysis for CY 2025 E/M Code List and includes the base Michigan Medicaid fiscal year 2025 FFS payment rates applicable to covered services. Consistent with 42 CFR § 447.203(b)(3)(i), payment rates are separated by population/age range, provider type, and geographic location only when the Medicaid payment rate varies in one or more of these categories.

For the purposes of this analysis, provider types with the same Michigan Medicaid FFS payment rates for a given CPT/HCPCS code have been consolidated into a single reporting category to reduce duplication in reporting. The ‘Non-Physician Behavioral Health Practitioner’ category includes licensed psychologists, licensed master’s social workers (LMSWs), licensed professional counselors (LPCs), licensed marriage and family therapists (LMFTs), and other non-physician behavioral health practitioners that share the same Medicaid FFS payment rate. The ‘Medical Practitioner’ category includes physicians, nurse practitioners, physician assistants, and other medical practitioners reimbursed under the same base Medicaid FFS payment rate for the applicable CPT/HCPCS code. Provider types with differing payment rates are reported separately. A similar methodology was utilized for the primary care CPT/HCPCs partition with the ‘Primary Care’ category only including primary care physicians, while the ‘Medical Practitioner’ category includes the previously mentioned provider types.

For CPT/HCPCS codes that are included in multiple CMS service categories (e.g., Primary Care, OB/GYN, and Outpatient MH/SUD), Medicaid claims and beneficiary counts in this report were limited to claims submitted by provider types relevant to the respective service category. This methodology was applied to avoid duplicate reporting across CMS service categories.

The analysis is limited to Michigan Medicaid FFS payment rates and utilization. Medicaid-paid claim counts and beneficiary counts represent calendar year utilization and are reported consistent with the requirements of 42 CFR § 447.203(b)(3)(i)(E).

HCBS Payment Rate Disclosure

The attached HCBS Payment Rate Disclosure was prepared in accordance with 42 CFR § 447.203(b)(3) and (4). The analysis lists Michigan Medicaid fee-for-service (FFS) payment rates for personal care and home health aide services along with the number of paid claims and Medicaid enrolled beneficiaries who received each service in CY 2025.  In MI Medicaid CY2025 and 2026, homemaker and habilitation services are only included in programs delivered via Managed Care, and not FFS; therefore, no FFS payment rates or utilization information is presented for those services.

The report is organized by the service level. Consistent with 42 CFR § 447.203(b)(3)(i), payment rates are separated by population/age range, provider type, and geographic location only when the Medicaid payment rate varies in one or more of these categories.  For personal care and home health aide services, Michigan uses statewide payment rates that do not vary by enrollee age. These services are only covered in non-facility settings, so Facility Base Rates are not reported.

Counts of claims and enrolled beneficiaries that received each service were identified as follows:

  • Personal care: (HCPCS) Procedure code T1019; payment rate is hourly.
  • Home health aide: Payment rate is per 15 minutes, so payment rates were multiplied by 4 to get the hourly rates reported.
    • Aide: G0156, revenue codes 0570-0572
      LPN: G0300, revenue codes 0550-0552
      RN: G02999, revenue codes 0550-0552              

The analysis is limited to Michigan Medicaid FFS payment rates and utilization. Medicaid-paid claim counts and beneficiary counts represent calendar year utilization and are reported consistent with the requirements of 42 CFR § 447.203(b)(3)(ii)(C).

 

  • Access Rule Report - Spreadsheet
    • This spreadsheet provides an analysis demonstrating compliance with the Medicaid Access Rule requirements and is organized into four tabs—Primary Care, OB/GYN, MH/SUD, and HCBS Payment Disclosure—to align with federal reporting expectations and to allow reviewers to easily locate the relevant data for each service category.