Health Finance Issues

Ensuring Sustainable Healthcare Funding

The MHA advocates for fair, adequate healthcare funding and helps hospitals navigate complex financing and reimbursement issues that impact access to care across Michigan communities.

Healthcare Reimbursement and Financing

Hospital and health system financing and reimbursement is complex and affects access to care in communities across Michigan. The MHA works on behalf of its members to achieve fair and adequate healthcare funding, and also helps hospitals communicate financial issues to the communities they serve.

Federal policy issuestriangle

Federal and State Hospital Finance Issues

The MHA monitors and engages with federal and state agencies that develop financing rules that direct hospital payments. These include payments for inpatient and outpatient services, value-based payments and fee-for-service payments. The MHA provides comments on key policy issues that impact the entire membership and/or significant subsets of the Michigan hospital community. MHA comments are shared with the membership through the Monday Report and direct email communications to assist members in developing their own comments to governmental agencies.

Hospital Association Reporting Portal (HARP)

HARP is a secure online portal that allows MHA-member hospitals to access hospital-specific information and submit documentation to the MHA.  For any questions, contact the health finance team at the MHA.

MHA Reporting Portal (HARP) Request Form

Medicare Rules 

Medicare rules set federal requirements for how hospitals deliver care to Medicare beneficiaries and receive payment for those services. The MHA works to ensure these policies support access to high-quality care and reflect the operational and financial realities hospitals face.

Fiscal Year 2026 Final Rules

These rules took effect Oct. 1, 2025:

  • Inpatient Prospective Payment System
  • Long Term Care Hospital
  • Inpatient Rehabilitative Facility
  • Inpatient Psychiatric Facility
  • Skilled Nursing Facility

2026 Medicare Proposed Rules

The Centers for Medicare & Medicaid Services (CMS) is expected to release final rules to update these around Nov. 1, prior to the Jan. 1, 2026 effective date.

  • Outpatient Prospective Payment System
  • Home Health
  • Physician Fee Schedule

Medicare Quality-Based Programs

DataGen provides an updated quality program reference guide annually following the release of the CMS final rules. The latest reference guide provides an overview of the FY 2026-2028 value-based purchasing (VBP), readmissions reduction and hospital-acquired condition (HAC) reduction programs.  The latest hospital-specific quality analyses are also available on HARP.

CMS Medicare Advantage

Medicare Advantage (MA) plans are privately administered alternatives to traditional Medicare that determine how beneficiaries access care and how hospitals are reimbursed. The MHA works to ensure these plans operate transparently, provide timely access to services and support fair, sustainable payment for hospitals.

CMS recently launched an online form to address MA issues. CMS uses the process to track complaints, inform future changes to MA plans and identify and escalate recurring trends as appropriate.

CMS sends completed forms to the MA plan identified and facilitates communication and resolution between the plan and provider. The plan has 30 days to work with the submitting provider to resolve the claims issue.

Providers will access the online complaint using the following steps:

  • Visit CMS website
  • Select “Medicare” from the top left dropdown menu
  • Select “Health & drug plans” from the left-hand navigation
  • Select “Report a provider complaint about an MA plan."

CMS created a mailbox to address provider complaints related to inappropriate utilization management criteria or claims processing approaches that may not comply with CMS requirements. This includes concerns related to prior authorization, concurrent review or retrospective review used to deny or downgrade coverage or payment that providers believe are not permitted under CMS rules.

Additonal Resources

Public Payor Enrollment

Medicare Advantage Enrollment

The MHA recently updated its analysis of Medicaid and Medicare enrollment based on February 2026 data. The analysis includes program enrollment as a percentage of each county’s total population and the split between fee-for-service and managed care organization. Just over 25% of Michigan’s total population is enrolled in Medicaid and 23% is enrolled in Medicare.

Roughly two-thirds of Michigan’s 2.5 million Medicaid beneficiaries are enrolled in one of nine managed care plans.

Total Medicare enrollment is 2.3 million with 64% of beneficiaries enrolled in a Medicaid Advantage (MA) plan with only three counties having less than 50% of total Medicare enrollment in MA plans. MA enrollment by county ranges from 44% to 79%, with 73 counties having 55% or more of their Medicare population enrolled in an MA plan as highlighted below.

February enrollment is spread across 45 MA plans with up to 29 plans covering beneficiaries in several Michigan counties, with a minimum of five plans available in each county.

Members with enrollment questions should contact the Health Finance team at the MHA.

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