"Second, Medicaid covers a lot of services that Medicare does not so there is not always a one-to-one comparison," he said.
"Third, it is difficult to compare your rate structures to other states, because if you've seen one Medicaid program you've seen one Medicaid program," he said. "There is so much variation in terms of the populations covered and how states cover them, the various waiver authorities they might use in their program designs, that states are finding it very difficult to make an apples-to-apples comparison."
The proposed rule was published last week in the Federal Register and public comments will be accepted for the next 60 days. Rollins said NAMD will offer comment on the proposal after speaking with its members.
John Commins is a senior editor at HealthLeaders.