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红领巾瓜报 Insights鈥攊ncluding briefs, webinars, and our podcast鈥攇ives you easy access to 红领巾瓜报鈥檚 deep expertise, helping you stay current on the latest healthcare trends and topics. Search for a topic of interest or browse the latest insights below.

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CMS Clarifies Grandfathering Rules for State Directed Payments

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The Centers for Medicare & Medicaid Services (CMS) last month issued a  to states providing preliminary guidance on  (SDPs), which outlines new federal payment limits, clarifies grandfathering provisions, and signals significant changes ahead for Medicaid financing and policy. The letter is part of CMS鈥檚 implementation of Section 71116 of the Budget Reconciliation Act of 2025 (, P.L. 119-21)鈥攖he portion of the legislation that focuses on curbing SDP spending and reinforcing program integrity.

Though CMS describes the guidance as preliminary, it is the view of 红领巾瓜报 (红领巾瓜报) experts鈥攊ncluding former state officials, actuaries, and policy strategists鈥攖hat it signals directionally new policy for Medicaid agencies, managed care organizations (MCOs), and providers. CMS is working on two proposed SDP-related regulations, which are in the final stages of federal review. The preliminary guidance and forthcoming rules will likely reflect long-standing concerns for several years, even over shifting congressional control and multiple presidential administrations.

This article addresses key clarifications in the letter; the impact of the preliminary guidance on states, MCOs, and providers; and how the directive may influence Medicaid budgets, financing strategies, and future policy reforms.

Guidance Clarifies Timeframes for SDPs

Grandfathering Limited to Specific Rating Periods

CMS will allow states to maintain SDP spending amounts, up to the average commercial rate ceiling, that were in place for state fiscal year (SFY) 2025, calendar year (CY) 2025, and SFY 2026 rating periods. Nonetheless, new or expanded SDPs above Medicare equivalent levels in expansion states and 110 percent of Medicare in non-expansion states鈥攅ven those based on legislation passed in 2025鈥攁re ineligible for grandfathering if they apply to rating periods starting after July 4, 2025. These grandfathered spending amounts will need to phase down with rating periods beginning on or after January 1, 2028.

Preliminary Grandfathering Determinations

CMS has begun notifying states whether a preprint is 鈥渓ikely eligible鈥 for grandfathering. Because these are preliminary determinations, states should prepare for further review and revisions.

Submission Cutoff Date Clarified

In response to confusion around the May 1, 2025, submission deadline, CMS clarified that July 4, 2025, is the cutoff for grandfathering eligibility, provided the state fully completed the preprint. States may have rushed to meet a July 4 submission deadline and may have left questions on the preprint unanswered. In these instances, it is possible鈥攊f not likely鈥攖hat CMS will consider the application incomplete and thus ineligible for grandfathering. Since this is a developing area with limited precedent, states may still seek clarification or reconsideration, though CMS has not yet issued definitive guidance or a formal process for resolving these situations.

No Increases Allowed Until 2028

States are prohibited from increasing the total dollar amount of grandfathered SDPs鈥攖he 鈥渆xpected spend鈥濃攗ntil January 1, 2028. This restriction limits flexibility for states to expand their programs and may require that they reassess their SDP strategies. For example, using percentage-based calculations tied to average commercial rates, will no longer capture year-to-year growth because of utilization or acuity changes.

10 Percent Phasedown Unaddressed

CMS has yet to provide official guidance on the 10 percent phasedown of SDPs. Stakeholders remain in a holding pattern, awaiting a forthcoming proposed rule that will clarify how reductions will be calculated.

What It Means for States and Healthcare Organizations

SDPs have become a critical tool for states to stabilize provider networks through increased Medicaid reimbursement. This authority will be significantly limited, and states will need to reduce many existing programs. Medicaid enrollment losses resulting from other Medicaid policy changes, such as work requirements and minimum semiannual redetermination, will likely compound the strain on provider payments.

Providers and states need to start planning for these losses in revenue now. Strategic planning for SDP sustainability and close monitoring of upcoming CMS rulemaking is essential.

While the guidance imposes constraints, it also opens the door for policy innovation. For example, some states may use this moment to reform Medicaid financing, streamline supplemental payments, and reconfigure provider incentives to better reflect quality and access, advancing value-based care goals and achieving total cost of care savings through efficiency and aligned incentives.

Connect with Us

红领巾瓜报 is uniquely positioned to support states, MCOs, and providers as they navigate the evolving landscape of Medicaid SDPs. Our team includes former state Medicaid directors, actuaries, and policy strategists with deep expertise in designing sustainable financing arrangements and guiding public engagement processes. We bring robust modeling capabilities to clients seeking to assess the financial impact of CMS鈥檚 new restrictions, including the 10 percent phasedown and interactions with provider tax limitations. Our experts are actively engaged with CMS and understand how to translate federal guidance into actionable strategies that align with state goals and operational realities.

Whether revising preprint submissions, evaluating quality frameworks, or rethinking provider incentives, 红领巾瓜报 delivers the technical and policy insight needed to move forward with confidence.

For questions about the federal guidance and considerations for your organization, contact our experts below.

Helping a Medicare Advantage Plan Identify Gaps in Part D Benefit Quality

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THE CLIENT

The client for this project is a health plan that provides both traditional Medicare Advantage (MA) plans and those that address chronic conditions and social determinants of health, to reduce healthcare disparities among historically underserved populations in the central and eastern United States. Their plans integrate Medicare Part A and Part B benefits with Part D prescription drug coverage, along with providing robust extra benefits.

BACKGROUND

MA Plans are assuming bigger risk in their Part D benefit spending than in previous years due to recent changes in MA rules. Audits of the program, a requirement to participate in MA, will mean that there are increased compliance and operational risks in how plans go about serving their members with the Part D benefit. As the regulatory environment changes, guarantees in pharmacy benefit manager (PBM) contracts need solidifying, and will require rigorous oversight by the plans to reduce risk. MA plans need to ensure alignment and collaboration across their organizations and with vendors to optimize initiatives in quality and Stars. It is also important to establish alignment and engagement early within the yearly bid cycle. T he client engaged 红领巾瓜报 due to our diverse expertise in Part D plans including operations, PBM and vendor oversight, health plan leadership, Stars and quality programs, financial and actuarial analysis, and compliance.

APPROACH

红领巾瓜报 performed an assessment to analyze and measure the effectiveness of Part D operations, including a comprehensive review of the plan鈥檚 Part D benefit, and identified gaps in Part D policies, procedures and staffing. The effort also documented operational efficiencies, quality improvement recommendations and opportunities for the client to increase their Part D Star ratings. 红领巾瓜报 identified areas of improvement and provided actionable insights to guide future decisions. The assessment utilized a combination of data, documents and interviews to cover various dimensions such as performance, compliance, effective oversight, and collaboration.

RESULTS

The final report recommended a series of organizational changes and quality improvements to enable the client to optimize their Part D operations. Recommendations were made in the following areas:

  • Policies and procedures: Identified gaps in the client鈥檚 internal policies and procedures, and provided recommendations to cure the deficiencies, including the development of desk-level guides.
  • Comprehensive oversight: Identified oversight gaps in vendor management and provided recommendations to improve.
  • Part D strategic leadership & proposed new staffing model: 红领巾瓜报 drafted a best-in-class organization and staffing plan that permits the client to scale up with a delineated staffing structure designed to ensure optimal oversight of Part D quality.
  • Collaboration: Identified gaps in PBM contracts and provided recommendations for negotiating and bolstering account management. The new plan also recommends expanding the Part D team鈥檚 role and involvement with provider engagement teams in order to increase overall CAHPS results to improve Star ratings.
  • Financial/actuarial analysis: Identified changing regulatory reporting (Direct and Indirect Remuneration) and capturing required information related to Manufacturer Discount Program (MDP) and Medicare Prescription Payment Plan (M3P).

HOW 红领巾瓜报 CAN HELP YOUR ORGANIZATION

If your organization wants to undertake a similar review of your Part D organization, we encourage you to engage with your teams to review and prioritize findings and recommendations to build out best practices and best in class plan operations. 红领巾瓜报 can help you develop a plan and guide you through the processes, identify issues that might not otherwise be identified internally, and provide recommendations for ways to optimize your efforts. Our team brings together expertise in Medicare Advantage, Part D, pharmacy, quality and accreditation programs, on the ground leadership experience in health plans, financial and actuarial expertise, with in-depth insider knowledge from our work in states across the country. Contact us to learn more about how 红领巾瓜报 can help.

红领巾瓜报 Enrollment Update: Medicaid Managed Care Organizations See Drop in Enrollment in 2Q25

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This week, our second In Focus provides insights into Medicaid managed care enrollment in the second quarter of 2025. 红领巾瓜报 Information Services (红领巾瓜报IS) obtained and analyzed monthly Medicaid enrollment data in 30 states,[1] offering a reliable baseline and timely view of the immediate impact of the current policy landscape as new federal policies take effect.

This analysis presents a snapshot of 红领巾瓜报IS鈥檚 comprehensive detailed quarterly Medicaid managed care enrollment report (available by subscription), which includes plan-level information for nearly 300 health plans in 41 states, corporate ownership, for-profit versus not-for-profit status, and similar information regarding publicly traded plans. Table 1 provides a sample of enrollment trends, representing 57 million Medicaid managed care enrollees of a total of 66 million Medicaid managed care enrollees nationwide. Data reporting periods and program coverage vary by state, so figures may not be fully comparable.

Key Insights from 2Q25 Data

The 30 states included in our review have released monthly Medicaid managed care enrollment data鈥攙ia a public website or in response to a public records request from 红领巾瓜报IS鈥攆or April through June of 2025. This report reflects the most recent data posted or obtained from states. 红领巾瓜报 has made the following observations regarding the enrollment data:

  • Year-over-year decline. As of June 2025, in the 30 states reviewed, Medicaid managed care enrollment declined by 1.6 million members year-over-year, a 2.7 percent drop from June 2024.
  • Widespread decreases. Of the 30 states, 27 experienced enrollment declines in June 2025 compared to June 2024. Oregon and the District of Columbia saw modest growth, while California remained flat (Table 1).
  • Sharpest contractions. Arizona and Maryland reported double-digit percentage drops in enrollment in June 2025 (Table 1), underscoring the uneven impact of redeterminations and eligibility policy changes.
  • Difference among expansion and non-expansion states. Among the 24 states included in the analysis that expanded Medicaid, enrollment fell by 1.2 million鈥攁 2.5 percent drop鈥攖o 49.2 million. The six non-expansion states saw a steeper proportional decline of 4.2 percent, to a total of 8 million enrollees.

Table 1. 2Q25 Monthly MCO Enrollment by State, April鈥揓une 2025

Note: 鈥+/- m/m鈥 refers to the enrollment change from the previous month, and 鈥% y/y鈥 refers to the percentage change in enrollment from the same month in the previous year.

The data in Table 1 should be viewed as a sampling of enrollment trends across these states rather than as a comprehensive comparison, which cannot be established based solely on publicly available monthly enrollment data. It is also important to note the limitations of the data presented. For example, not all states report data at the same time during the month, resulting in a range of snapshots from the beginning to the end of the month. Second, in some instances, the data cover all Medicaid managed care programs, while in others they reflect only a subset of the broader managed Medicaid population, depending on what data is publicly available.

Market Share and Plan Dynamics

红领巾瓜报IS鈥檚 report includes plan-level details for nearly 300 plans, covering corporate ownership, program participation, and tax status. As of June 2025, Centene continues to lead the national Medicaid managed care market with 17.8 percent share, followed by Elevance (10.4 percent), United (8.6 percent), and Molina (6.2 percent; see Table 2).

Table 2. National Medicaid Managed Care Market Share by Number of Beneficiaries for a Sample of Publicly Traded Plans, June 2025

What to Watch

The OBBBA (P.L. 119-21) calls for significant changes to Medicaid eligibility and enrollment policies, including work requirements and more frequent eligibility redeterminations.  indicate that Medicaid and Children鈥檚 Health Insurance Program enrollment could decline by up to 7.5 million people by 2034. In addition, the Centers for Medicare & Medicaid Services (CMS) has announced that it will not approve or extend waivers for multi-year continuous eligibility for adults or children.

As these policies are implemented, state governments and healthcare organizations should prepare for increased administrative complexity, potential coverage disruptions, and the resulting effect on MCO revenue and value-based care arrangements.

Connect with Us

红领巾瓜报 is home to experts who know the Medicaid managed care landscape at the federal and state levels. As the Medicaid landscape continues to evolve, 红领巾瓜报IS equips stakeholders with timely, actionable intelligence, including enrollment data, quarterly by-plan and by-state enrollment reports, financials, Medicaid demonstration and Rural Health Transformation program tracking, and a robust library of publicly available Medicaid-related documents. 红领巾瓜报IS combines publicly available information with 红领巾瓜报 expert insights on the structure of Medicaid in each state, as well as our comprehensive, proprietary State Medicaid Overviews.

For questions about the 红领巾瓜报IS enrollment report and information about the 红领巾瓜报IS subscription, contact our experts below.

Finding a Path to Support Aging in Place in California聽

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New 红领巾瓜报 report discusses the unmet needs of older adults in low-income housing, highlighting the challenges of siloed programs and the difficulty in blending services

Research consistently shows that more than 70 percent of Americans want to age in place, remaining in their own homes. Yet the country鈥檚 shifting demographics, rising costs for long-term services and supports, and changing financing landscape make achieving this goal more challenging than ever, especially for low-income older adults. In fact, more than one-quarter million older Californians live in senior affordable housing developments that range in size from a few dozen apartments to over a thousand units in large high rises. Most striking was the finding that while many of these residents are not only low-income and disproportionately burdened with chronic disease and also dually eligible for Medicaid and Medicare鈥攁 group shown in countless studies to represent a considerable proportion of Medicare and Medicaid costs, but that few residents appear to participate in aligned Medicare and Medicaid special needs plans (D-SNPs) or to access Medi-Cal waiver services.

The report gathers direct input from older adults, including Asian populations, in eight languages, addresses critical funding gaps, and identifies policy priorities that if implemented offer innovative recommendations for California to reduce duplication and better serve older adults using current resources.

ABA Compliance and Strategic Policy Support for Medicaid Managed Care Organizations

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红领巾瓜报 Spotlight

ABA Compliance and Strategic Policy Support for Medicaid Managed Care Organizations

Applied Behavior Analysis (ABA) is an evidence-based behavior therapy for people with autism spectrum disorder (ASD) and other developmental disorders. In recent years, the diagnosis of ASD and subsequent demand for ABA services has increased. State Medicaid administrations and Managed Care Organizations (MCOs) are tracking increased ABA utilization and wait times for these services, and in some situations are investigating quality of care and/or fraud, waste, and abuse (FWA) concerns. To optimize quality care for members, MCOs who cover these services must have policies regarding ABA benefit structure, clinical guidelines, utilization management, and service delivery. Plans also need to monitor for and identify possible FWA concerning documentation and/or billing practices for these services. MCOs with comprehensive ABA compliance and auditing programs can meet these critical needs.

Our team

红领巾瓜报鈥檚 national presence keeps us at the forefront of ABA-related changes in multiple states. 红领巾瓜报鈥檚 team of behavioral health clinicians have years of experience conducting FWA audits and have specific training required to conduct detailed and meticulous ABA reviews. Our team includes operational and clinical subject-matter experts with board certifications in behavior analysis (BCBA, RBT) who can support auditing activities as well as policy review and revision. We will work with your organization鈥檚 team to provide the insights necessary to maximize ABA quality of care and cost efficiency.

How 红领巾瓜报 can help

We work closely with MCOs to develop a customized scope of services that meet their unique ABA compliance, policy, and strategy needs.

We can help MCOs with:

  • Establishing their own ABA compliance programs
  • Conducting audits of ABA provider claims and associated medical records, using customized audit tools and findings reports, to identify potential FWA, including as part of an MCO鈥檚 Special Investigation Unit (SIU) program
  • Reviewing and providing feedback on ABA-related policies
  • Developing ABA-related documentation forms
  • Providing consultation on ABA reimbursement/utilization benchmark development
  • Providing support in building cohesion/collaboration between MCO and local Department of Developmental Disabilities representatives
  • Developing strategies to improve care coordination for youth transitioning to adulthood
  • Assisting MCOs with their Managed Behavioral Healthcare Organizations (MBHO) benefit oversight
  • Demonstrating how to maximize the interface of organizational Early and Periodic Screening, Diagnostic and Treatment (EPSDT) Medicaid benefits and the intersection with ABA services

We produce results

Our auditing team members have supported the SIUs of three Medicaid health plans in different states. We have demonstrated a 12:1 return on investment for our clients, based on associated recoupment of improper payments and estimated prevented loss.

If you have questions about our ABA compliance, policy, or strategic support services, contact our experts below.

ABA Auditing Services聽Case Study

Contact our experts:

Headshot of Nicole Lehman

Nicole Lehman

Associate Principal

Nicole Lehman is an experienced healthcare professional specializing in the improvement, development, and growth of multifaceted, high-paced managed care organizations. … Read more
Headshot of Shannon Walters

Shannon Walters

Associate Managing Director

Webinar Replay – Navigating Medicaid Managed Care Shifts: Financial Pressures, Federal Policy, and Medicaid MCO Implications

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This webinar was held on September 17, 2025.

Medicaid managed care organizations face mounting pressure as enrollment patterns shift, federal policy evolves, and state budgets tighten. In this webinar, experts from 红领巾瓜报IS, Wakely, and 红领巾瓜报 shared exclusive analysis of Medicaid Managed Care Organization (MCO) financial performance, explored the implications of HR 1 and other federal policies, and offered State and MCO perspectives.

Learning Objectives

  • Interpret 2024 Medicaid MCO financial trends and historical benchmarks to anticipate future market performance.
  • Assess how federal policy changes, including HR 1, are reshaping Medicaid enrollment and creating new fiscal pressures for States and MCOs.
  • Evaluate state considerations around risk corridors, medical loss ratios (MLRs), and similar mechanisms in a challenging budget environment.
  • Identify strategies and planning initiatives that promote resilience, sustainability, and adaptation for Medicaid managed care organizations in a shifting landscape.

This webinar was for Medicaid managed care leaders, state officials, vendors, budget officers, and investors navigating financial pressures and policy shifts.

Applied Behavior Analysis (ABA) Auditing Services聽

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THE CLIENT

红领巾瓜报鈥檚 team of expert behavioral health auditors from Crestline Advisors performs audits of behavioral health services, including applied behavior analysis (ABA) services, for a Medicaid health plan in Virginia (鈥渢he client鈥). The client refers cases to 红领巾瓜报 when there are allegations of possible fraud, waste, or abuse (FWA) concerning documentation and/or billing practices for these services.

BACKGROUND

ABA is an evidence-based behavior therapy for people with autism spectrum disorder (ASD) and other developmental disorders. In recent years, the diagnosis of ASD and subsequent demand for ABA services has increased. State Medicaid administrations and Managed Care Organizations (MCOs) are tracking increased ABA utilization and wait times for these services, and in some situations are investigating quality of care and/or FWA concerns. Types of FWA concerning ABA therapy services may include billing for services not rendered, billing for ABA services without documentation of ABA-specific interventions, billing for services by unqualified individuals, or billing more units than the documentation supports, to name a few. We have a deep bench of licensed behavioral health clinicians and coders with many years of experience in conducting audits for MCOs, state Medicaid administrations, and providers. Given our expertise, we understand the importance of the golden thread of documentation that should underlie billing, including assessments and treatment plans which identify the need for ABA services and documentation of ABA service interventions, supervision, and family training.

APPROACH

The client鈥檚 SIU team identifies providers of ABA services for whom there is an allegation of potential FWA and provides us with sample claims and medical records to review. We have developed customized audit tools to investigate the unique documentation and billing considerations for ABA. Incorporating state-specific provider/billing manual requirements, we conduct pre- and post-pay audits in which we may identify errors in documentation (misalignment with what is billed on the claim). We then provide a detailed report to the client summarizing the identified errors and potential improper payments. Our team also can assist in the pre-audit phase to develop provider communications to request medical records and provides post-audit support to MCOs to help explain findings to providers impacted by the audit, or to support the MCO in an appeal or fair hearing process.

RESULTS

This is an ongoing project that has already provided significant value to our client in a short period of time. The client鈥檚 analysis of our auditing work, which included ABA findings reports as well as findings reports for other behavioral health services, has already identified a 12:1 return on investment, based on associated recoupment of improper payments and estimated prevented loss. Our own internal ROI analysis, focused specifically on ABA audits, also identified a 12:1 benefit. By working with our team, MCOs can expect to see timely and thorough identification of potential improper payments upon which they may act to reduce FWA. Ultimately, reducing FWA leads to increased availability of services for the members who need them most and promotes improved quality of care from qualified professionals. To learn more, email .

Medicaid Managed Care Profitability: Navigating Margin Pressures and Regulatory Shifts in 2024

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This week, our In Focus section highlights findings from 红领巾瓜报 Information Services鈥 (红领巾瓜报IS鈥檚) review of 2024 statutory filings submitted to the National Association of Insurance Commissioners (NAIC). These filings provide a nationwide view of Medicaid managed care plan profitability and medical loss ratios (MLRs) across 221 plans operating in 39 states, the District of Columbia, and Puerto Rico.

These data build upon and offer additional context to a previous  conducted by 红领巾瓜报 and Wakely, an 红领巾瓜报 Company, of increasing post-pandemic financial pressures driven by acuity increases resulting from the continuous eligibility unwinding and increases in behavioral health and home and community-based services access and utilization.

Medicaid Managed Care Underwriting Gains and Losses

As state Medicaid programs have increasingly moved from fee-for-service to managed care, a foundational assumption has been that efficient managed care organizations (MCOs) reduce waste and deliver high quality, cost-effective healthcare services. This transition has made Medicaid plan performance and sustainability a central focus for policymakers and actuaries alike.

Medicaid capitation rates must be actuarially sound, which means they must be projected to cover all 鈥渞easonable, appropriate, and attainable costs,鈥 including medical administrative costs, plus a margin for insurance risk, even for nonprofit plans. According to the Society of Actuaries 2024 , average underwriting margins in Medicaid rates ranged from 0.35 percent to 3.15 percent, with a consistent average between 1.2 percent and 1.3 percent.

However, actual results often deviate from projections for reasons that may be challenging to predict. Rate setting is an inherently forward-looking process, and even with conservative assumptions, unexpected shifts in enrollment, acuity, or service utilization can lead to significant deviations from projected results. Retrospective reviews show variability in margins over time (see Figure 1).

Figure 1. Historical Medicaid MCO Net Gains/Losses, 2012鈥2024 (39 States, DC)

Based on 红领巾瓜报IS鈥檚 analysis, Medicaid MCOs sustained modest but steady gains from 2012 through 2017. After a decline between 2016 and 2019, margins rebounded to approximately 3 percent until 2022, narrowed in 2023 to 1.9 percent, and turned negative in 2024 at -0.9 percent.

For the first time in over a decade, more plans experienced losses than gains in 2024 (see Figure 2), with only 42 percent reporting positive margins, down from the decade high of 84 percent in 2022. This shift raises critical questions about sustainability and participation in Medicaid managed care.

Figure 2. Medicaid Managed Plans Likelihood of Gain, 2012鈥2024 (39 States, DC)

The 鈥淟ikelihood of Gain鈥 chart tracks the percentage of Medicaid managed care plans reporting an underwriting gain each year from 2012 to 2024. For most years, the likelihood that a plan posted a gain was relatively high, typically between 60 percent and 80 percent. The probability reached a recent peak in 2022, with 84 percent of plans reporting gains, and remained elevated in 2023 (74 percent). In 2024, however, the likelihood of gain dropped sharply to just 42 percent, the lowest level in the 12-year period.

Risk Corridors, Medical Loss Ratios, and Structural Policy Shifts

MLRs show the portion of plan revenue spent on medical care as compared with the costs to operate the plan and the underwriting gain or loss described previously. When MLRs rise or fall, it can be an indication that medical cost trends experienced by health plans differ from the assumptions used by state rate setting actuaries. High MLRs are the key driver of underwriting gains, and low MLRs are associated with higher profitability. All states report MLRs to the Centers for Medicare & Medicaid Services (CMS), and some enforce minimum MLRs with a remittance provision, requiring plans to return funds if their MLR goes below a certain level.

Risk corridors are another tool that states use to manage financial volatility. These mechanisms share gains or losses between plans and states when results deviate significantly from pricing assumptions, offering protection to MCOs and the state alike, in contrast to minimum MLR provisions with a remittance provision, which only protects the state. During the COVID-19 pandemic, many states implemented or expanded risk corridors to recoup overpayments because of lower utilization. Some risk corridors were set retroactively鈥攁 practice CMS now prohibits.

In 2024, MLRs reached a decade high of 90.8 percent, as indicated by 红领巾瓜报IS鈥檚 analysis. Driving this increase were heightened utilization rates, increased enrollee acuity, and the end of continuous Medicaid coverage protections in 2023. As healthier, lower-cost members left Medicaid, plans were left serving a more complex population with higher per-member costs. Inflation in medical costs鈥攅specially for behavioral health and home and community-based services鈥攁dded more pressure. Delayed or avoided care during the COVID-19 pandemic may also have played a role, as members sought more services in 2022鈥2024, resulting in a surge in utilization greater than what was priced into rates.

Many states put risk corridors in place to stabilize margins from 2020 to 2022, which may have contributed to the tight band of outcomes around the high underwriting gains in that period. However, many states have been  them for 2024, 2025, and 2026. Without these protections, plans may face greater exposure to underpayment in 2025 and 2026 if cost trends continue to outpace rate assumptions.

What to Watch

Rate setting conversations between states and plans for 2026 are happening now, and in many cases they are quite challenging. In addition to meeting actuarial soundness requirements, states also must balance their budgets, and some may be facing limitations on their traditionally used tools.

Looking ahead, it will be increasingly important that states and plans partner to find cost savings that can ensure the program鈥檚 long-term sustainability.

A subscription to 红领巾瓜报IS provides access to comprehensive financial intelligence on Medicaid managed care. Far beyond surface-level snapshots, 红领巾瓜报IS delivers health plan-level financial performance metrics, enrollment trends, and state policy developments that directly shape rate setting and operational strategy. Whether you鈥檙e a state official, health plan executive, or policy strategist, 红领巾瓜报IS provides the financial clarity and policy context needed to anticipate regulatory shifts, benchmark performance, and make confident, data-driven decisions.

For questions about the analysis discussed in this article, contact our experts below.

Los Angeles County Child Welfare-Involved Population Medi-Cal Analysis

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Comparative Analysis of the Engagement in Care for Children in Medi-Cal Fee-for-Service vs. Managed Care and Learnings from Enhanced Care Management Early Implementation

In November 2023, the Los Angeles (LA) County Board of Supervisors passed a motion to address the implementation of new benefits for the child welfare-involved population launched through California鈥檚 Medicaid waiver, California Advancing and Innovating Medi-Cal, known as CalAIM. The CalAIM waiver expanded services to managed care beneficiaries, including enhanced care management (ECM) for coordinated case management, referrals, and community resource navigation and community supports, such as housing assistance, medically tailored meals, housing modifications, respite care for caregivers, and asthma management. These benefits are designed to better address health and social needs for the most vulnerable and at risk Medi-Cal beneficiaries, including children and youth involved in the child welfare system. The Board directed the Office of Child Protection (OCP), in collaboration with key county departments, to engage 红领巾瓜报, Inc. (红领巾瓜报), as the technical assistance provider.

Recognizing that approximately two-thirds of child welfare-involved children and youth in LA County are enrolled in fee-for-service (FFS) Medi-Cal and ineligible for new CalAIM supports, 红领巾瓜报 conducted a comparative analysis of the experience of children involved in the child welfare system in FFS versus managed care Medi-Cal through an analysis of federal T-MSIS data looking at a snapshot of data from December 2022. The analysis examined the experience of the child welfare-involved population in primary and preventive healthcare services (including well-child visits, dental visits, behavioral health) in Medi-Cal FFS versus managed care plan enrollment (MCPs) to inform decisions about existing practices for care management among the child welfare-involved population. The comparative analysis of the child welfare population in Los Angeles County, San Diego County, and Riverside County revealed children in managed care consistently showed higher rates of engagement in primary and preventative healthcare services.

Disaggregating Managed Care Payments: New Insights into Medicaid Spending

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As states and stakeholders seek greater transparency and accountability in Medicaid, a new analysis from 红领巾瓜报 (红领巾瓜报), offers a fresh perspective on how dollars flow through the system. Drawing on publicly available data from the Transformed Medicaid Statistical Information System (T-MSIS), 红领巾瓜报 disaggregated funding dispersed to Medicaid managed care organizations to discern spending for specific categorically eligible populations. The findings significantly enhance policy discussions and can facilitate development of pragmatic and specific care management interventions that support quality patient care.

For policymakers, regulators, and other stakeholders, this level of disaggregation provides a clearer view of how public dollars are used鈥攁nd where there may be opportunities to improve performance or reinvest savings. It also supports more informed rate development and contract negotiations, particularly as states pursue value-based purchasing and other reforms. As Medicaid continues to evolve, especially in the context of budget pressures and changes in enrollment and risk profiles of enrollees, understanding the financial picture of managed care programs is essential to ensuring sustainability.

红领巾瓜报鈥檚 team of experts鈥攊ncluding actuaries, former Medicaid directors, and data analysts鈥攈as deep experience working with T-MSIS data and advising states, plans, and providers on Medicaid program analysis, evaluation, and strategy. For more information about working with T-MSIS data and the insights it can provide, contact聽our experts below.

Medicaid Managed Care Enrollment Update 鈥 Q1 2025

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In this week鈥檚 In Focus section, 红领巾瓜报 Information Services (红领巾瓜报IS) draws on its database of monthly enrollment in Medicaid managed care programs to provide the latest quarterly analysis of Medicaid managed care enrollment, offering a snapshot of developments across 28 states. [1] The data and insights are particularly timely as stakeholders, including states, Medicaid managed care organizations (MCOs), hospitals and health systems, and providers, continue to plan for multiple possible federal policy changes and the operational realities that will follow.

红领巾瓜报IS also compiles a more detailed quarterly Medicaid managed care enrollment report representing nearly 300 health plans in 41 states. The report provides by plan enrollment plus corporate ownership, program inclusion, and for-profit versus not-for-profit status, with breakout tabs for publicly traded plans. Table 1 shows a sampling of plans and their national market share of Medicaid managed care beneficiaries based on a total of 66 million enrollees. These data should be viewed as a broader representation of enrollment trends rather than as a comprehensive comparison.

Key Insights from Q1 2025 Data

The 28 states included in our review have released monthly Medicaid managed care enrollment data via a public website or in response to a public records request from 红领巾瓜报 (红领巾瓜报). This report reflects the most recent data posted or obtained.  红领巾瓜报 has made the following observations related to the enrollment data:

  • Year-over-year growth. As of March 2025, across the 28 states reviewed, Medicaid managed care enrollment declined by 2.5 million members year-over-year, a 3.9 percent drop as of March 2025 (see Figure 1). This marks a continuation of the downward trend reported in late 2024, though with notable variation across states.

Figure 1. Year-over-Year Growth in Medicaid Managed Care States, 2020鈭24, March 2025

  • Localized growth amid broader declines. While most states experienced enrollment reductions, Indiana and North Carolina bucked the trend with measurable gains, suggesting the influence of state-specific policy shifts or demographic factors. Oregon and Texas also saw modest growth.
  • Sharpest contractions. Illinois, Maryland, and South Carolina, reported double-digit percentage drops, underscoring the uneven impact of redeterminations and eligibility changes.
  • Difference among expansion and non-expansion states. Among the 21 states included in our analysis that expanded Medicaid, enrollment fell by 1.8 million (-3.6%) to 48.6 million. In contrast, the seven non-expansion states saw a steeper proportional decline (-5.4%), to a total of 12.2 million enrollees.

Table 1. Monthly MCO Enrollment by State, January 2025 through March 2025

Note: In Table 1 above and the state tables that follow, 鈥+/- m/m鈥 refers to the enrollment change from the previous month, and 鈥% y/y鈥 refers to the percentage change in enrollment from the same month in the previous year.

It is important to note the limitations of the data presented. First, states report the data at the varying times during the month. Some of these figures reflect beginning of the month totals, whereas others reflect an end of the month snapshot. Second, in some instances, the data are comprehensive in that they cover all state-sponsored health programs that offer managed care options; in other cases, the data reflect only a subset of the broader managed Medicaid population. This limitation complicates comparison of the data described above with figures reported by publicly traded Medicaid MCOs. Hence, the data in Table 1 should be viewed as a sampling of enrollment trends across these states rather than a comprehensive comparison, which cannot be established solely based on publicly available monthly enrollment data.

Market Share and Plan Dynamics

Using our data repository from 300 health plans across 41 states, 红领巾瓜报IS鈥檚 report addresses corporate ownership, program participation, and tax status. As of March 2025, Centene continues to lead with 17.7 percent of the national Medicaid managed care market, followed by Elevance (10.8%), United (8.8%), and Molina (6.3%), as Table 2 shows.

Table 2. National Medicaid Managed Care Market Share by Number of Beneficiaries for a Sample of Publicly Traded Plans, March 2025

What to Watch

The policy backdrop remains fluid. The US House of Representatives鈥 passage of the One Big Beautiful Bill Act introduces sweeping changes to Medicaid financing, including proposed cuts of up to $715 billion. Additional federal proposals, such as mandatory work requirements, could further reshape enrollment patterns.

Stakeholders should prepare for:

  • Implementation of work/community engagement mandates for certain adult populations
  • Potential redesign of Affordable Care Act expansion programs
  • Retraction of federal regulations focused on streamlining of eligibility and redetermination processes to improve accuracy and efficiency

Connect with Us

红领巾瓜报 is home to experts who know the Medicaid managed care landscape at the federal and state levels. As the Medicaid landscape continues to evolve, 红领巾瓜报IS equips stakeholders with timely, actionable intelligence. Our subscription service includes enrollment data, financials, waiver tracking, and a robust library of public documents.

For more information about the 红领巾瓜报IS subscription, contact our experts below.

[1] Arizona, California, Florida, Georgia, Illinois, Indiana, Kentucky, Louisiana, Maryland, Michigan, Minnesota, Mississippi, Missouri, Nevada, New Jersey, New Mexico, New York, North Carolina, Ohio, Oregon, Pennsylvania, South Carolina, Tennessee, Texas, Virginia, Washington, West Virginia, Wisconsin.

Disaggregating Managed Care Payments Provides Opportunities for New Insights into Medicaid Spending for Critical Populations

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红领巾瓜报 focused this paper on how states disperse Medicaid funds to certain subpopulations within the program鈥檚 categorical eligibility infrastructure. A previous companion paper centered on increasing our understanding of Medicaid managed care spending by provider, offering more detail on the relative order of magnitude of the amounts spent on inpatient and outpatient hospital care, professional services, long-term care, pharmacy, and other health services.

As the latest national Medicaid managed care enrollment data show 75% of Medicaid beneficiaries were enrolled in comprehensive managed care organizations (MCOs), these two foundational papers illustrate the importance of developing a sound methodology to reliably estimate costs associated with MCOS. These papers, which are the first to present findings related to the development of the MCO methodologies, help lay the foundation for further work that will enable us to answer relevant questions, including:

  • How much do we spend on Medicaid patients with chronic conditions like asthma, diabetes, and hypertension?
  • How much do we spend on Medicaid patients receiving long-term services and supports (LTSS) and what is the unmet need?
  • How is Medicaid funding spent on childbirth and a child鈥檚 first year of life?
  • What are the opportunities to be more efficient and effective with Medicaid resources?
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