Making Sense of the Medicaid Access Rule: What It Means for States, Providers, and the Direct Care Workforce
In May 2024, CMS finalized the Medicaid Access Rule — a landmark regulation designed to improve transparency, strengthen oversight, and expand access across Medicaid services. While it covers a broad set of changes, one provision in particular has the potential to reshape how policy is made at the state level: the requirement to create Interested Parties Advisory Groups (IPAGs) that include direct care workers (DCWs) and consumers.
For the first time, the federal government is requiring states to bring the workforce to the table in rate-setting and access decisions.
What Is the Medicaid Access Rule?
The Access Rule is CMS’s effort to ensure that Medicaid beneficiaries can actually obtain the services they are entitled to. It strengthens state accountability in three areas:
Payment Adequacy and Transparency – States must publish payment rates for certain services and justify them against cost data.
Oversight of Access – New requirements for monitoring wait times, provider participation, and network adequacy.
Stakeholder Engagement – Establishment of IPAGs to bring consumers, family caregivers, providers, and direct care workers into the policy process.
Source: Centers for Medicare & Medicaid Services (CMS), Medicaid Access Rule Final Rule, 2024.
The New Advisory Group Requirement
The rule requires every state Medicaid agency to:
Establish an Interested Parties Advisory Group (IPAG).
Ensure membership includes direct care workers, consumers, family caregivers, and providers.
Use these groups to inform rate setting, access monitoring, and program design.
This marks a significant shift. Traditionally, states have relied on provider associations, managed care organizations, or consumer advocates for input. Now, frontline workers must be formally included.
Why This Matters for States
States will need to:
Recruit and retain diverse worker voices — ensuring the group reflects different job roles (home care, residential aides, DSPs, CNAs), demographics, and geographies.
Provide support — compensation for time, travel stipends, translation/language access, disability accommodations, and flexible scheduling.
Facilitate meaningful engagement — training members on how Medicaid policy works, what “rate setting” means, and how to reach consensus.
Done well, IPAGs can strengthen trust between workers and state agencies while providing insights that lead to more realistic and effective policies. Done poorly, they risk being tokenistic and underutilized.
Why This Matters for Providers
Providers should view IPAGs not as compliance hurdles, but as opportunities:
Stronger workforce retention: Workers who feel heard are more likely to stay in the field.
Better-informed rate policy: Worker feedback can highlight the true costs and challenges of service delivery.
Visibility for the sector: Advisory groups elevate the role of direct care work as a profession, not just a job.
Providers may also want to prepare by:
Identifying workers who could participate in IPAGs.
Supporting staff with training and paid release time.
Tracking how state agencies are forming these groups and offering feedback.
Why This Matters for Workers and Consumers
For DCWs, this is a rare acknowledgment at the federal level that their voices matter in Medicaid policy. It creates a pathway for workers to influence wages, training, scheduling, and safety.
For consumers and families, the inclusion of worker perspectives can lead to better continuity of care and more sustainable service models. When workforce realities are reflected in policy, recipients benefit.
My Reflection
The Medicaid Access Rule doesn’t fix the workforce crisis — but it does create a new lever. By requiring worker and consumer voices at the table, CMS has given states an accountability mechanism they can’t ignore.
For organizations like PHI, and for states like Maine, Indiana, and Kentucky that are already experimenting with advisory groups, this is a moment to scale what works. For providers, it’s a chance to support workers in becoming leaders and advocates.
The challenge now is execution. Advisory groups must be designed thoughtfully, with real support, diversity, and follow-up. If done right, they could become one of the most important workforce policy tools of the next decade.
