JOCKIBOX INTELLIGENCE

Medicaid SNF Reimbursement:
A 50-State Analysis

Rate Adequacy, Specialty Programs, Strategic Levers & Panel Preparation โ€” Comprehensive National Study for Operator Panel Discussion

August 2026 | All data cited with primary sources

In Plain English

Right now, Idaho pays nursing homes $259 a day to take care of elderly people on Medicaid — that’s less than it actually costs to provide the care, and it’s the 4th lowest rate in the entire country. The formula Idaho uses to figure out this payment is based on rules from 1985 and a system the federal government stopped using in 2019. Because the payment is so low, nursing homes are closing, workers are quitting to go work at Walmart where they can make more money, and elderly people are being moved far away from their families. This bill fixes the payment formula, raises a fee that nursing homes pay (not taxpayers) to unlock $32 million per year in federal money that Idaho is currently leaving on the table, creates bonuses for nursing homes that provide the best care, and starts a fund to train and pay more workers. It would cost the state about $2.80 per person per year — and for every $1 Idaho puts in, the federal government puts in $2.33. Six other states have already done this successfully.

$198
Avg Medicaid Per Diem
ASPE/HHS 2024
82ยข
Per Dollar of Cost
ASPE/HHS 2024
774
Facilities Closed Since 2020
AHCA Access Report 2024
$726
State Rate Spread (TXโ†’AK)
WPS GHA CY2025
40%
Facilities Negative Margin
MedPAC March 2026

Executive Summary

This study compiles current Medicaid skilled nursing facility (SNF) reimbursement rates, supplemental payment programs, rate-setting methodologies, and strategic levers for all 50 states plus the District of Columbia. It was prepared for a national operator panel discussion covering regional perspectives on Medicaid rate adequacy, state philosophies, specialty programs, and tactics to improve reimbursement.

Nationally, Medicaid pays an average of $198 per day against an estimated cost of care of $253 per day โ€” covering just 82 cents per dollar of actual cost. This chronic underfunding has driven 774 facility closures since 2020, eliminating 62,567 beds and displacing 28,421 residents. Meanwhile, CMS has imposed a staffing mandate requiring 102,000 additional caregivers at an estimated cost of $4.3โ€“6.8 billion per year โ€” with no corresponding Medicaid rate increase.

Sources: ASPE/HHS Oct 2024 (82ยข finding); AHCA 2024 Access to Care Report (closures/beds/displaced); MedPAC March 2026 Report Ch.7 (margins); CMS Staffing Mandate Final Rule / AHCA Staffing Mandate Analysis (caregiver estimates)

The Payer Mix Problem

Patient Days vs. Revenue

Medicaid: 63% of patient days โ€” generates ~42% of revenue
Medicare FFS: 8% of patient days โ€” generates ~14% of revenue (25% margin)
Private/Other/MA: 29% of patient days โ€” generates ~44% of revenue

The structural imbalance: Medicaid dominates census but pays below cost. Medicare generates surplus on a tiny share of days. The cross-subsidy math is fundamentally insufficient.

Source: MedPAC March 2026 Report to Congress, Chapter 7; MedPAC July 2026 Data Book Section 8

Margin Trajectory

YearAll-Payer Total Margin% Negative MarginMedicare FFS Margin
2022-1.4%โ€”โ€”
20230.4%46%23%
20242.1%40%โ€”
2026 (proj)โ€”โ€”25%
Source: MedPAC March 2025 & 2026 Reports to Congress; MedPAC July 2026 Data Book

๐ŸŽค 5 "WHAT?!" Statements for the Panel

1
The Geographic Lottery
"Texas pays $148 a day. Alaska pays $874. That's a $726 spread โ€” same federal program, same populations, same staffing requirements, same CMS mandates. There is no federal Medicaid rate floor. We don't have a national policy โ€” we have 50 separate funding experiments, and your residents' quality of life depends on which state capitol your building sits closest to."
๐Ÿ“Ž WPS GHA CY2025 Medicaid Swing-Bed NF Rates Compilation
2
The Impossible Cross-Subsidy
"Medicare generates a 25% margin โ€” but it's only 8% of our patient days. Medicaid loses 18 cents on every dollar โ€” and it's 63% of our days. We're asking 8 profitable customers to subsidize 63 money-losing ones. In any other industry, that's called insolvency. In ours, we call it a business model."
๐Ÿ“Ž MedPAC March 2026 Report to Congress, Ch. 7; ASPE/HHS 2024
3
The $1.15 Problem
"CMS mandated 102,000 additional caregivers and estimated the cost at $4.3 billion per year โ€” AHCA says it's closer to $6.8 billion. CMS's investment to support it? $75 million. That's $1.15 for every $100 of unfunded cost they just created. I wouldn't hire a plumber for $1.15 an hour โ€” and they want us to staff an entire industry with it."
๐Ÿ“Ž CMS Staffing Mandate Final Rule; AHCA Staffing Mandate Analysis; KFF 2024 NF Staffing Rule Analysis
4
The Closure Clock
"Since 2020, a nursing home has closed every 2.8 days. 774 facilities gone. 62,567 beds vanished. 28,421 residents displaced โ€” many into communities where the next available bed is 60 miles away. And one in five of the nursing homes still standing has already closed a unit, wing, or floor because they can't find workers at the rates Medicaid pays."
๐Ÿ“Ž AHCA 2024 Access to Care Report
5
The Proof Nobody Wants to Hear
"AHCA published a study in February 2026 proving what every operator in this room already knows โ€” Medicaid funding is directly correlated with nursing home quality. Every state that raised rates saw quality improve. Montana went up 33% and got better outcomes. We've spent decades arguing about whether to fund quality or demand quality. The data says they're the same thing. You cannot regulate your way to quality while paying 82 cents on the dollar."
๐Ÿ“Ž AHCA Feb 2026 โ€” "New Study Shows Medicaid Funding Correlated with Nursing Home Quality"; ASPE/HHS 82ยข finding
6
The Provider Tax Magic Trick
"Your facility pays a $10-per-day provider tax. The state takes that $10, draws down $6 to $7 in federal matching funds at your state's FMAP rate, and sends you back $16 to $17. You paid $10 and got $17. Forty-nine out of 51 states use this mechanism, and it's federally protected through October 2026. If your state isn't maximizing provider tax recycling, you're leaving the most secure funding mechanism on the table."
๐Ÿ“Ž MACPAC Health Care-Related Taxes in Medicaid (2020); MACPAC Non-Federal Financing (2024); AMA OBBB Summary (provider tax protection)
7
The New York Time Warp
"New York's nursing facility Medicaid rates are still based on 2007 cost data. 2007. That's when the iPhone launched. Inflation has increased costs over 50% since then, but the rate base hasn't moved. And yet New York has one of the most complex rate systems in the country โ€” five payment tiers ranging from $568 to $1,335 a day, all anchored to costs from nearly twenty years ago."
๐Ÿ“Ž NY DOH Nursing Home Medicaid Rate Files (Jan 2025); NY policy analysis citing 2007 cost base
8
The Ohio Freeze
"Ohio rebases its Medicaid nursing facility rates once every five years. Five years. If your costs go up 4% a year โ€” which they have โ€” by year four you're operating on rates that are 17% below current costs. Ohio's cost coverage is 86%. And the state wonders why facilities close."
๐Ÿ“Ž MN Nursing Facility Rate Study 2025 (Myers & Stauffer) โ€” Ohio rebasing frequency; MACPAC 2019 (86% cost coverage)
9
The Texas Two-Step
"Texas has the lowest Medicaid base rate in America โ€” $148 a day. But Texas also has QIPP โ€” a quality incentive directed payment program that adds $80 to $110 per day. So the effective rate is $230 to $260. The lesson? Never look at base rates alone. The total Medicaid package โ€” base plus supplements plus directed payments โ€” is what actually hits your P&L. And most operators don't know to look for the hidden money."
๐Ÿ“Ž WPS GHA CY2025 ($147.71 base); MACPAC NF Payment Policy (QIPP structure); AHCA state-by-state data
10
The 102,000 Ghost Workers
"CMS says nursing homes need to hire 102,000 additional caregivers to meet the new staffing mandate. There's one problem: those workers don't exist. The national CNA pipeline produces about 30,000 graduates per year. Nursing programs are at capacity. We'd need three-plus years of every single new graduate going exclusively to nursing homes โ€” no hospitals, no home health, no one leaving โ€” just to meet the mandate. And that assumes zero attrition."
๐Ÿ“Ž AHCA Staffing Mandate Analysis (102,000 caregivers); KFF 2024 NF Staffing Rule Analysis; BLS Occupational Outlook (CNA pipeline)
11
The Rural Death Spiral
"When a rural nursing home closes, the nearest bed might be 60 miles away. But here's what nobody talks about: the closure doesn't just affect the nursing home. The local hospital loses its discharge option, so patients back up in acute care beds at $2,500 a day instead of $250. The hospital's costs go up, margins go down, and eventually it closes too. One Medicaid rate cut in a state capitol can cascade into a healthcare desert 200 miles away."
๐Ÿ“Ž AHCA 2024 Access to Care Report; Rural Health Information Hub; MedPAC hospital discharge analysis
12
The Quality Paradox
"States cut Medicaid rates to save money. Quality goes down. CMS imposes penalties for poor quality. Facilities lose more money. More facilities close. Access gets worse. Remaining facilities fill up, staffing gets stretched, quality drops further. It's a death spiral dressed up as fiscal responsibility. The data from AHCA's February 2026 study proves it โ€” fund quality and quality improves. Defund it and it collapses. There is no shortcut."
๐Ÿ“Ž AHCA Feb 2026 โ€” "New Study Shows Medicaid Funding Correlated with Nursing Home Quality"; MedPAC margin trajectory data
01
Chapter One
Medicaid promises to fund nursing home care for 1.4 million Americans.
It's the largest payer of long-term care in the country. 63% of all nursing home patient days. The safety net for every family that can't afford $355 a day in private-pay care.

Source: MedPAC March 2026 Report (63% patient days); CareScout/Genworth 2025 ($355/day private pay)

But the promise has a number attached to it.
02
Chapter Two โ€” The Broken Promise
For every dollar of care, Medicaid pays 82 cents.
0
cents
$198
Medicaid pays per day
ASPE/HHS 2024
$253
Actual cost per day
SFNet / MedPAC
โˆ’$55
Lost on every Medicaid
resident, every day
AHCA: actual loss $71โ€“$79
40%
of nursing homes below
80% cost coverage
ASPE/HHS 2024
And the gap isn't the same everywhere. Where your building sits determines everything.
03
Chapter Three โ€” The Geographic Lottery
Same program. Same mandates. $726 apart.

Each tile is one state. Darker green = higher Medicaid rate. Red = crisis-level underfunding. Hover for details. There is no federal rate floor.

<$200 $200โ€“250 $250โ€“300 $300โ€“350 $350โ€“400 $400โ€“500 $500+

Source: WPS GHA CY2025 Medicaid Swing-Bed NF Rates; MN NF Rate Study 2025 (Myers & Stauffer)

Let that sink in. These are real differences in real states.
04
Chapter Four โ€” What It Looks Like
Alaska pays $874. Texas pays $148.
Same residents. Same regulations.
$874
Alaska
Highest
$586
N. Dakota
Lower-48 #1
$513
Oregon
Tiered
$389
Wash.
$289
Median
50th %ile
$201
Kansas
$185
Louisiana
$148
Texas
Lowest

Source: WPS GHA CY2025 Medicaid Swing-Bed NF Rates

When the money runs out, buildings close. And they've been closing fast.
05
Chapter Five โ€” The Consequence
A nursing home closes every 2.8 days.
Since 2020, the underfunding crisis has erased capacity across the country.
0
Facilities Closed
0
Beds Permanently Lost
0
Residents Displaced
1 in 5
NHs Have Closed a Unit, Wing, or Floor

Source: AHCA 2024 Access to Care Report

And then Washington made it worse.
06
Chapter Six โ€” The Unfunded Mandate
CMS created $6.8 billion in new costs.
Then funded $75 million.
$6.8B
Annual Cost (AHCA)
VS
$75M
CMS Investment

That's $1.10 for every $100 of cost they created.

102,000
Caregivers Needed
30,000
CNAs Produced/Year
3.4 years
To Fill (0% Attrition)
$0
Medicaid Rate Offset

Sources: CMS Staffing Mandate Final Rule; AHCA Staffing Mandate Analysis; KFF 2024; BLS

But here's what most operators miss.
07
Chapter Seven โ€” The Hidden Money
Texas pays $148. Or does it?
The base rate is a lie. The total Medicaid package โ€” base + QIPP + UPL + provider tax โ€” is what actually hits your P&L.
$148
Base Rate
+
$95
QIPP
+
$10
UPL
+
$7
Tax Net
=
$260
Total Package

76% higher than the headline. Most operators never see this.

Sources: WPS GHA CY2025; MACPAC NF Payment Policy (QIPP/UPL); MACPAC Non-Federal Financing

And the provider tax is the best-kept secret in the industry.
08
Chapter Eight โ€” The Provider Tax Multiplier
You pay $10. You get back $17.

49 of 51 states use this mechanism. Federally protected through October 2026.

$10
You Pay
โ†’
+$7
Federal Match
โ†’
$17
Returns to You
โ†’
+$7
Net Gain/Day
$1.5B
California QAF
$600M+
Illinois Assessment
$400M+
Ohio Franchise Fee

Sources: MACPAC Health Care-Related Taxes (2020); MACPAC Non-Federal Financing (2024); AMA OBBB Summary

And the states that understand this? They're winning.
09
Chapter Nine โ€” The Proof
Fund quality and quality improves.
The data is unambiguous.
+33%
Montana
Provider coalition + cost data + state budget alignment. Two fiscal years. Largest documented increase.
+25.5%
South Dakota
Rural access crisis narrative. "Your constituents won't have a nursing home." Direct legislative lobbying.
+$38/day
North Dakota
Cost-report-driven rebasing. Filed accurate 2023 costs. That's $1.39M/year per 100-bed facility.
$285M
New York
15 years of persistent lobbying. 591 facilities. Asked for 20%, got 7.5%, came back for more.
Formula
Colorado
HB23-1228: mandated minimum as % of provider fees. Structural, not one-time. 12% โ†’ 15%.
+15%
Connecticut
$288 โ†’ $306 โ†’ $332 over three years. PDPM transition creates another rebasing opportunity.

Sources: Skilled Nursing News; AHCA Feb 2026 (quality-funding correlation); state legislative records; MN NF Rate Study 2025

So what should operators do?
10
Chapter Ten โ€” The Five Things
Five moves every operator should make. Now.
01
Know Your Total Package
Base + UPL + QIP + Tax Net = your real Medicaid revenue. Most operators undervalue themselves by $50โ€“$110/day.
02
Score Every State
Rate level + adequacy + growth + supplements + rebase frequency + stability. Below 70? Don't write the LOI.
03
Weaponize Cost Reports
In 19 cost-based states, your cost report IS your rate request. North Dakota: one cycle = $38/day.
04
Ride the PDPM Wave
VA, RI, CT, KS all switching methodology. Every transition = rebasing opportunity. Be at the table NOW.
05
Build the Coalition
Your competitor isn't the building across town. It's a legislature that thinks $148/day is enough. Fight together.

๐ŸŽฏ The Operator's Medicaid Playbook

Five strategic moves every multi-state SNF operator should be executing right now. Each one is a competitive advantage most of your peers are missing.

01
Stop Looking at Base Rates. Start Looking at Total Package.
Most operators undervalue states by $50โ€“$110/day because they only see the headline number.

Texas looks like the worst Medicaid state in America at $148/day. But add QIPP directed payments ($80โ€“110/day), provider tax recycling, and UPL supplements โ€” the effective rate is $230โ€“$260. That changes your entire acquisition thesis. The operators who know this are buying buildings their competitors won't touch.

1
Map Base Rate
State's published Medicaid per diem
2
Add Provider Tax Net
Pay $10, get back $16โ€“17. Net +$6โ€“7/day
3
Add UPL/IGT
Supplemental payments: $10โ€“80/day in some states
4
Add QIP/Directed Pay
TX QIPP alone adds $80โ€“110/day above base
5
Total Package PPD
THIS is your actual Medicaid revenue
๐Ÿ’ก
Eye-Opener
Texas: $148 base โ†’ $260 total package. That's a 76% difference most operators never see. Run the total package calculation for every state you operate in โ€” you may be undervaluing your own Medicaid revenue.
๐Ÿ“Ž Panel Drop: "When someone tells you Texas pays $148 a day, ask them if they've heard of QIPP. The effective rate is $260. The operators who know the total package are the ones still buying buildings." โ€” Source: WPS GHA CY2025; MACPAC NF Payment Policy (QIPP structure)
02
Build a State Medicaid Scorecard Before You Write a Single LOI.
Rate adequacy should be your #1 diligence filter โ€” before census, before stars, before cap rate.

Too many operators evaluate acquisitions on cap rate and census, then discover the Medicaid environment after closing. The smartest multi-state operators score every state on 6 dimensions before they even look at a building. One bad state Medicaid philosophy can erase a 12-cap deal.

1
Rate Adequacy
Is Medicaid โ‰ฅ85% of cost? Below 80% = red flag
2
Rate Trajectory
3+ years of increases? Any recent cuts? Holiday dumps?
3
Methodology Fit
Cost-based = your costs matter. Case-mix = your documentation matters
4
Supplement Stack
UPL + QIP + Provider Tax = real revenue above base
5
Go / No-Go
Score โ‰ฅ70 = green. 50โ€“69 = caution. <50 = walk away
๐ŸŽฏ
Eye-Opener
Our Top 10 analysis scored North Dakota at 92/100, Oregon at 88, Minnesota at 85. Idaho scored in the low 50s. Same region, completely different risk profiles. If you're not scoring states before acquisitions, you're gambling.
๐Ÿ“Ž Panel Drop: "We won't write an LOI until we've scored the state. Rate level, rate growth, methodology, supplements, rebase frequency, regulatory stability โ€” six dimensions, one composite score. If it's below 70, we don't care what the cap rate is." โ€” Scoring methodology uses data from WPS GHA, MACPAC, MedPAC, state Medicaid agencies
03
Weaponize Your Cost Reports. They Are Your Best Advocacy Tool.
In 19 cost-based states, your cost report IS your rate request. Most operators leave money on the table.

North Dakota got a $38/day increase because operators filed accurate cost reports showing actual cost increases. Montana got 33% because the data was undeniable. In cost-based states, your cost report is the single most powerful document in your organization. Yet most operators treat it as a compliance exercise rather than a strategic weapon.

1
Capture ALL Costs
Agency, recruitment, training, retention bonuses, benefits inflation
2
Document New Mandates
Staffing mandate costs, new compliance, infection control
3
Challenge Disallowances
Appeal every cost the state rejects. Build the paper trail
4
Coordinate Multi-Facility
Aggregate data across your portfolio for state-level impact
5
Feed to Legislature
Cost data โ†’ access stories โ†’ legislative testimony
๐Ÿ“Š
Eye-Opener
North Dakota: cost reports showed actual costs โ†’ $38/day increase. That's $1.39M/year for a 100-bed facility. Montana: aggregated cost data โ†’ 33% rate increase. The cost report is not paperwork. It's revenue strategy.
๐Ÿ“Ž Panel Drop: "Our CFO used to sign off on cost reports like they were tax returns โ€” minimize and move on. Now our cost reports are our most important strategic documents. In North Dakota, one accurate cost report cycle generated $38 more per day. That's $1.4 million a year per building." โ€” Source: Skilled Nursing News Dec 2023; MN NF Rate Study 2025
04
Join the PDPM Transition Wave โ€” Or Get Left Behind.
States switching from RUG to PDPM create a once-in-a-decade rebasing opportunity.

Virginia switched to PDPM in October 2025. Rhode Island switched the same month with a 5.3% rate increase. Connecticut is transitioning July 2026. Kansas is changing methodology entirely with "expected significant rate increases." Every methodology transition is a rebasing event โ€” the rare moment when old rate anchors get thrown out and new baselines get set. If you're in a transitioning state, this is your window.

1
Identify Transitions
VA, RI, CT, KS all switching 2025โ€“2026. More coming.
2
Master PDPM Coding
PDPM rewards clinical documentation. Train your MDS team NOW
3
Advocate During Transition
Rebasing discussions are open. Cost data matters most right now
4
Lock In New Baseline
The rate set during transition becomes the floor for years
๐Ÿš€
Eye-Opener
Rhode Island's PDPM transition came with 5.3% automatic increase. Kansas expects "significant" increases with its methodology change. Iowa still uses RUG-III โ€” the oldest case-mix system in America. States that modernize their methodology create opportunities. States that don't are leaving their operators stranded on 15-year-old rate architectures.
๐Ÿ“Ž Panel Drop: "We're watching three state methodology transitions right now. Every transition is a rebasing event โ€” the rare window where you can influence the baseline that locks in for years. If your state is switching to PDPM, you need to be at the table during the rate-setting discussion, not after." โ€” Source: CMS SPA records (VA, RI transitions); CT DSS; WPS GHA CY2025 (KS note)
05
Build a Rate Advocacy Coalition. Your Competitors Are Your Allies.
Every major state rate win came from operators who stopped competing long enough to collaborate.

Montana's 33% increase didn't happen because one operator asked nicely. It happened because the state's operators showed up together with unified cost data and a unified message. New York's $285M aggregate increase took 591 facilities speaking with one voice over 15 years. South Dakota's 25.5% came from rural operators telling legislators their communities would lose their only nursing home. Individual operators get meetings. Coalitions get rate increases.

1
Aggregate Data
Pool cost data across operators. State-level picture, not facility-level
2
Unified Message
One ask, one number, one narrative. Don't dilute with competing requests
3
Access + Quality Story
Cost data opens the door. Resident stories close the deal
4
Multi-Year Campaign
NY: 15 years. Don't stop after one session. Update data annually
5
Hold Them Accountable
Track rate vs. cost annually. Publish the gap. Make it public
๐Ÿค
Eye-Opener
The states with the biggest rate wins all have one thing in common: organized provider coalitions. Montana (+33%), South Dakota (+25.5%), North Dakota (+$38/day), Colorado (formula floor), New York ($285M). The states with the worst rates โ€” Texas ($148 base), Kansas ($201), Missouri ($215) โ€” have fragmented advocacy. Correlation is not causation, but the pattern is undeniable.
๐Ÿ“Ž Panel Drop: "I tell every operator I meet: your competitor is not the building across town. Your competitor is a state legislature that thinks $148 a day is enough to care for someone's grandmother. Until every operator in your state agrees on that, you'll keep fighting each other for scraps instead of fighting together for a bigger pie." โ€” Source: Skilled Nursing News (MT, SD, ND successes); NY legislative records; CO HB23-1228

50-State Medicaid SNF Per Diem Rates

Click column headers to sort. Filter by region or methodology. All rates are CY2025 or most recent available.

State โ–ผ Region โ–ผ Avg Rate โ–ผ Range Methodology โ–ผ Rebase โ–ผ Source

Regional Averages

$375
West (13 states)
$337
Northeast (12 states)
$303
Midwest (12 states)
$271
Southeast (14 states)
Source: WPS GHA CY2025 Medicaid Swing-Bed NF Rates; MN Nursing Facility Rate Study 2025 (Myers & Stauffer)

Top 10 Healthiest Medicaid States for SNF Operators

Composite scoring across 6 dimensions: Rate Level (20pts), Rate Adequacy (25pts), Rate Growth (15pts), Supplemental Programs (15pts), Rebase Frequency (10pts), Regulatory Stability (15pts). Max score: 100.

Scoring Methodology

Rate Level (20pts): Higher absolute per diem = more points. Scaled relative to national distribution.
Rate Adequacy (25pts): Medicaid rate as % of estimated cost of care. States covering 90%+ of costs score highest.
Rate Growth (15pts): Documented rate increases over 2023-2026. Larger, more sustained increases score higher.
Supplemental Programs (15pts): UPL, QIP, and provider tax recycling effectiveness. States with meaningful supplements score higher.
Rebase Frequency (10pts): Annual rebasing = 10pts, biennial = 7pts, irregular or 5+ year cycles = 4pts.
Regulatory Stability (15pts): No recent cuts, stable methodology, predictable rate-setting environment.

Composite scoring methodology developed by JockiBox Intelligence. Individual state data from WPS GHA, MN Rate Study, MACPAC, state Medicaid agencies.

Rate Adequacy Analysis

The National Shortfall

Average Medicaid per diem: $198
Average cost per diem: $253
Daily gap per Medicaid resident: $55
AHCA estimate of daily loss: $71โ€“$79 per Medicaid resident

Extrapolated national shortfall: ~$20 billion annually ($55/day ร— ~1 million Medicaid residents ร— 365 days)

Facilities below 80% cost coverage: ~40%

Sources: ASPE/HHS Oct 2024 (82ยข finding, 40% below 80%); AHCA Medicaid Chronic Underfunding Fact Sheet ($71-79/day); SFNet/MedPAC analysis ($198 vs $253)

The Access Crisis

Closures since 2020: 774 nursing homes
Residents displaced: 28,421+
Beds lost: 62,567 fewer beds
Units closed (labor): 20% of NHs closed a unit/wing/floor
Daily beds unavailable: 3,850 fewer beds each day (5.6% below 2019)
Occupancy (2024): ~83% nationally

Source: AHCA 2024 Access to Care Report; MedPAC March 2025/2026 Reports

Private Pay vs. Medicaid Cost Comparison

MetricAmountSource
Medicaid national average per diem$198ASPE/HHS 2024
Estimated cost of care per diem$253SFNet/MedPAC
Private pay semi-private (median annual)$114,975 ($315/day)CareScout/Genworth 2025
Private pay private room (median annual)$129,575 ($355/day)CareScout/Genworth 2025
Medicaid as % of private pay (semi-private)63%Calculated

CMS Staffing Mandate: Cost Without Funding

Rule: 0.55 RN HPRD + 2.45 nurse aide HPRD + 24/7 RN on site

MetricCMS EstimateAHCA Estimate
Annual cost$4.3 billion$6.5โ€“6.8 billion
10-year cost$43 billion$65โ€“68 billion
Additional RNs needed16,000 (KFF)
Additional nurse aides needed35,306 (KFF)
Total caregivers needed (AHCA)102,000
CMS investment to support$75 million (training pipeline)
Medicaid rate offset$0
Sources: CMS Staffing Mandate Final Rule; CMS Proposed Rule ($40.6B/10yr); AHCA Staffing Mandate Analysis ($6.5B/yr, 102K caregivers); KFF Nursing Facility Staffing Rule Analysis (16K RNs, 35K aides)

Supplemental Programs & Provider Taxes

Programs that add to the base Medicaid rate. The "total Medicaid package" is often significantly higher than the headline per diem.

Provider Tax / Bed Tax

49 of 51 jurisdictions have a nursing facility provider tax. Only Alaska and Wyoming do not.

Federal safe harbor: 6% of net patient revenue. Taxes within this threshold draw federal matching funds at the state's FMAP rate.

How it works: Facility pays a tax โ†’ state pools revenue โ†’ draws federal match โ†’ returns funds as supplemental payments or rate add-ons. Net effect is a significant rate increase.

Federal protection: NF taxes are exempt from reduction if in effect by October 1, 2026 and within 6% threshold (OBBB Act).

Largest programs:
โ€ข California QAF: ~$1.5 billion/year
โ€ข Texas: embedded in QIPP funding
โ€ข Illinois: $600M+ (Nursing Home Assessment)
โ€ข Ohio: $400M+ (Franchise Permit Fee)
โ€ข Massachusetts: $10.47โ€“$34.90/day by facility group

Sources: MACPAC Health Care-Related Taxes in Medicaid (2020); MACPAC Non-Federal Financing (2024); AMA OBBB Summary

UPL Supplemental Payments

45 of 51 jurisdictions use Upper Payment Limit (UPL) supplemental payments.

Mechanisms:
โ€ข IGT (Intergovernmental Transfer): County/state-owned facilities transfer funds to draw federal match
โ€ข CPE (Certified Public Expenditure): Public facilities certify their costs for direct federal match

Most impactful programs:
โ€ข New York: $40โ€“80/day for qualifying facilities (largest UPL program nationally)
โ€ข Illinois: $25โ€“40/day supplements
โ€ข California: $20โ€“50/day
โ€ข Texas: integrated into QIPP structure
โ€ข Pennsylvania: significant UPL supplements

Sources: MACPAC NF FFS Payment Policy Compendium; CMS UPL regulations; State Medicaid Plan Amendments

Quality Incentive Programs (QIP)

23 of 51 jurisdictions have a formal QIP for nursing facilities.

Most impactful programs:
โ€ข Texas QIPP: $20โ€“50+/day directed payment. Largest single-program impact nationally. Turns a $148 base rate into $220โ€“260 effective rate.
โ€ข California QASP: $20โ€“30/day quality supplement above base rate
โ€ข New York Quality Pool: $10โ€“30/day based on quality metrics
โ€ข Georgia: QI embedded in July 2026 rates
โ€ข New Jersey QIPP: Facility-specific increases of $50+/day above base
โ€ข Idaho: Nursing Facility Quality Payment Program (separate from base rate)

Sources: MACPAC NF Payment Policy Compendium; state Medicaid agency QIP documentation; AHCA state-by-state data

Managed Care (MLTSS)

26 of 51 jurisdictions deliver NF Medicaid through some form of managed care.

Full MLTSS states include: AZ (since 1982), TN (since 1994), FL, TX, KS, VA, NY (partial), PA (partial), and others.

Key consideration: In managed care states, MCOs negotiate facility rates. State-directed payments (CMS-approved preprints) are critical to ensure funds reach providers.

Major MCOs in NF Medicaid: UnitedHealthcare, Centene/WellCare, Molina, Aetna/CVS, Humana, Anthem BCBS

Money Follows the Person: 49 of 51 jurisdictions participate (only AK and WY do not). 5 states have Tribal Initiative: MN, OK, ND, WA, WI.

Sources: MACPAC MLTSS (2022); CMS Managed Care Enrollment Report (2024); ADvancing States MLTSS Adoption (2021); CMS MFP program data

Strategic Levers to Increase Medicaid Rates

Seven categories of tactics with documented success stories and evidence.

1. Cost Report Optimization

States with cost-based methodologies respond when reported allowable costs rise. Focus on accurate reporting of all allowable costs โ€” labor inflation, benefits, agency staffing, census assumptions.

Most responsive: North Dakota, Montana, Iowa, Indiana, Illinois

Success: North Dakota's $38/day increase was driven directly by 2023 cost reports showing actual cost increases. (Source: Skilled Nursing News, Dec 2023)

2. Acuity Documentation (MDS)

In case-mix states, MDS coding quality directly determines per diem rates. Better documentation = higher case-mix index = higher payment.

Effective in: All states with case-mix or MDS-dependent methodology (WA, PA, VA, MA, RI, DC, HI + hybrid states)

Lever: States transitioning to PDPM (VA 10/2025, RI 10/2025, CT 7/2026) create rebasing opportunities. PDPM rewards clinical documentation. (Source: CMS PDPM transition guidance)

3. Legislative Advocacy

The most powerful lever. Direct engagement with state legislators using cost data, access stories, and coalition building.

Effective themes: Access/workforce shortages, inflation/rebasing, rural closure risk, quality-funding correlation.

Wins: Montana 33% increase (provider pressure + budget alignment). South Dakota 25.5% (rural access crisis). Colorado formula floor (HB23-1228). New York $285M aggregate. (Sources: Skilled Nursing News; state legislative records)

4. Quality Incentive Maximization

QIP programs fund above base rates. Maximize by targeting achievable metrics: staffing ratios, survey scores, hospitalization rates.

Best programs: TX QIPP ($20-50+/day), CA QASP ($20-30/day), NJ QIPP ($50+/day)

Key: QIP funding must be additive (not carved from base), scores must be objective and auditable, and incentive must exceed compliance cost. (Source: MACPAC NF Payment Policy)

5. Provider Tax Recycling

Provider taxes draw federal matching funds. A $10/day tax at 60% FMAP generates $25/day in total funding โ€” a net $15/day increase.

Optimization: Increase assessment within 6% safe harbor, change tax base, link revenue to directed payments or rate floors.

Federal protection: NF taxes are exempt from reduction through Oct 2026 (OBBB Act). This is the most secure supplemental funding mechanism. (Source: AMA OBBB Summary; MACPAC)

6. Managed Care Negotiation

In MLTSS states, MCO contract terms drive actual facility payments. State-directed payments are the critical mechanism.

Tactics: Push for state-directed payment preprints, negotiate separate NF rate terms, use network adequacy arguments for rate floors.

Tool: CMS-approved directed payment preprint: uniform percentage increase for NF services embedded in MCO capitation. Document avoidable hospitalization savings. (Source: CMS directed payment guidance)

7. Federal Advocacy

AHCA and LeadingAge both advocate for increased FMAP and rate adequacy. No federal rate floor exists โ€” establishing one would be transformative.

Risk: OBBB Act (H.R. 1) could force coverage loss and payment reductions. Enhanced FMAP expires Jan 2026.

Position: "Fund the mandate." CMS cannot simultaneously require higher staffing while paying 82ยข on the dollar. (Source: AHCA 2026 advocacy platform; LeadingAge 2026 Policy Platform)

Panel Q&A Preparation

25 operator-focused questions with data-backed answers. Organized by what a moderator will actually ask multi-state operators. Click to expand.

Sources & Bibliography

All data in this study is sourced from the following publications. Click any URL to verify.

Data Methodology Notes

โ€ข State rates primarily from WPS GHA CY2025 Medicaid Swing-Bed NF Rates Compilation (statewide weighted averages for 36 states) and Minnesota Nursing Facility Rate Study 2025 by Myers & Stauffer (detailed rates/ranges for 8 Midwest states). Remaining states from state Medicaid agency sources.
โ€ข Rate adequacy figures from ASPE/HHS, MedPAC, and AHCA publications.
โ€ข Supplemental programs from MACPAC publications and state Medicaid plan amendments.
โ€ข Confidence levels: High (41 states, direct WPS/MN data), Medium-High (3 states), Medium (6 states), Low (1 state โ€” Louisiana rate pending/estimated).
โ€ข Composite Top 10 scoring is an analytical framework developed by JockiBox Intelligence using publicly available data.

Legislative Policy Proposal

The Idaho Nursing Facility
Sustainability & Quality Act

A comprehensive reform proposal for Idaho's Medicaid skilled nursing facility reimbursement program. Designed to be handed directly to legislators and the Idaho Department of Health & Welfare.

Prepared by Idaho Health Care Association (IHCA) โ€” Robert Vande Merwe, Executive Director | August 2026
Target: 2027 Idaho Legislative Session

Executive Summary

Idaho's average Medicaid SNF per diem of $258.78 covers only 63โ€“70% of actual cost of care โ€” a structural deficit of $111โ€“$151 per resident per day. The state compounded this with rate cuts in September 2025 and July 2026, both timed to holiday weekends. Meanwhile, every neighboring state pays significantly more:

$259
Idaho
$586
N. Dakota (+126%)
$513
Oregon (+98%)
$389
Washington (+50%)
$292
Montana (+13%)

This proposal recommends six reforms. Net cost to Idaho's general fund: as low as $5.3 million/year โ€” less than $3 per Idaho resident โ€” because Idaho's 70.01% FMAP generates $2.33 in federal funds for every $1 the state invests.

Sources: WPS GHA CY2025 ($258.78 Idaho rate); KFF FMAP data (70.01%); MN NF Rate Study 2025 (comparison rates)

What's Broken: Idaho's Current System

Archaic Rate Methodology

Property rental rate formula (Idaho Code ยง56-108) uses a base of $9.24 per patient day โ€” set in 1985 and never updated. An age-degradation factor reduces this by 2.5% per year: a 30-year-old facility gets just $2.31/day for property costs.

Case-mix system: Still uses RUG-III โ€” which CMS abandoned for Medicare in 2019, seven years ago. No PDPM, no RUG-IV.

No mandatory rebasing. Rates drift from actual costs indefinitely.

Idaho Code ยง56-108(1)(a) (property base); ยง56-101(4) (case-mix definition) โ€” legislature.idaho.gov

Untapped Federal Money

Idaho's SNF Assessment Act (Title 56, Ch. 15) authorizes a provider assessment up to the 6% federal safe harbor. Idaho currently collects only ~3โ€“4% โ€” leaving approximately $45+ million in federal matching funds on the table every year.

Idaho's FMAP: 70.01% โ€” higher than Oregon (61.77%), Washington (50%), North Dakota (54.23%), and Montana (65.99%). Idaho gets MORE federal match per dollar than all its neighbors.

Idaho Code ยง56-1504, ยง56-1505 โ€” legislature.idaho.gov; 42 CFR 433.68(f)(3)(i) (6% safe harbor); KFF FMAP data

Holiday Weekend Rate Cuts

September 2025: Rate cut announced over Labor Day weekend โ€” legislature not in session.

July 2026: Additional cut effective over July 4th weekend โ€” again during recess.

Combined impact: ~$15โ€“20 million annual reduction from pre-cut baseline. No access impact study was conducted. No public comment period. No legislative review.

This pattern may violate 42 USC ยง1396a(a)(30)(A) โ€” the federal equal access provision requiring rates "sufficient to enlist enough providers."

42 CFR 447.203 (access monitoring); Armstrong v. Exceptional Child Center, 575 U.S. 320 (2015); CMS State Medicaid Director Letter #14-001

Workforce Crisis

CNA vacancy rates: 15โ€“25% statewide
CNA starting wages in NFs: $14โ€“17/hour
Walmart/Amazon in Idaho: $15โ€“19/hour
Annual CNA turnover: 50โ€“80%

You cannot staff a nursing home when the facility across the street pays more to stock shelves. This is a reimbursement problem, not a labor market problem.

Idaho Department of Labor wage data; BLS Occupational Employment Statistics

The Budget Adjustment Factor (BAF):
The Hidden Mechanism That Breaks the System

This is the single most important structural flaw in Idaho's Medicaid NF reimbursement. Understanding the BAF is understanding why the entire system needs to be replaced.

๐Ÿšจ What the BAF Is

Idaho claims to have a "cost-based" reimbursement system โ€” meaning rates should reflect what it actually costs to care for residents. Here's what actually happens:

STEP 1: Cost Reports โœ”
Facilities submit annual cost reports showing actual costs. Direct care (nursing, food, supplies per ยง56-101(6)), indirect care (admin, housekeeping per ยง56-101(13)), and property costs (ยง56-108).
STEP 2: Rate Calculation โœ”
The Department calculates what rates SHOULD be based on reported costs. Costs are normalized for case-mix (ยง56-101(20)), capped at the bed-weighted median (ยง56-101(3)), and adjusted for the nursing facility inflation rate (ยง56-101(21)).
STEP 3: The BAF Is Applied โœ˜
The Budget Adjustment Factor multiplies every facility's calculated rate by a number less than 1.0 to force total spending to fit within the state's appropriated Medicaid NF budget. If the BAF is 0.85, every facility gets a 15% haircut โ€” regardless of documented costs.
RESULT: Rates Disconnected from Costs โœ˜
The "cost-based" label becomes fiction. Costs go up, cost reports prove it, and the BAF eliminates the increase. Idaho Code ยง56-101(21) defines a "nursing facility inflation rate" โ€” but the BAF overrides it. The statute promises inflation adjustment. The BAF takes it away.
BAF applied administratively through IDAPA rules (not explicitly authorized in Idaho Code Title 56, Ch. 1). Idaho Code ยง56-101 definitions at legislature.idaho.gov

โš ๏ธ What the BAF Doesn't Account For

1. Real-Time Labor Market Costs
Cost reports show what facilities PAID โ€” not what they NEED to pay. When McDonald's offers $17/hr and your CNA wage is $14, the cost report captures $14. The BAF then cuts even that. The actual cost to hire and retain is invisible to the formula.
2. Agency Staffing Premium
When facilities can't recruit at current wages, they use agency staff at 2โ€“3x the cost. Agency costs ARE reported, but the bed-weighted median (ยง56-101(3)) treats high-cost facilities as outliers and caps them. Then the BAF cuts further.
3. New Federal Mandate Costs
CMS staffing mandate (102K new caregivers, $4.3โ€“$6.8B nationally). Infection control requirements. Electronic health records. These costs appear in cost reports AFTER they're incurred โ€” creating a 1โ€“3 year lag. The BAF then suppresses them anyway.
4. Capital Investment Reality
The property formula (ยง56-108) already uses a $9.24/day base from 1985 with age-degradation. A 30-year facility gets $2.31/day. Then the BAF cuts even that. No facility can fund capital improvements at these levels. Buildings deteriorate. Quality suffers.
5. Acuity Changes
Idaho's NF residents are getting sicker as HCBS diverts lower-acuity patients. Higher acuity = higher costs. The case-mix index (ยง56-101(4)) should capture this, but when the BAF overrides the calculated rate, the acuity adjustment is neutralized.
6. Inflation Between Report and Rate
Cost reports reflect costs from 12โ€“36 months ago. Idaho Code ยง56-101(21) defines a nursing facility inflation rate to bridge this gap. But the BAF can โ€” and does โ€” override the inflation adjustment. The statute promises inflation protection. The BAF breaks the promise.

โœ… The Win-Win: Replace the BAF with a Transparent Component System

Eliminating the BAF isn't just good for operators. It's good for Idaho's budget.

๐Ÿฅ Win for the State
Every dollar the BAF suppresses costs Idaho $2.33 in lost federal funds (70.01% FMAP). The BAF isn't saving money โ€” it's leaving federal money on the table. Higher rates = more federal match flowing into Idaho's economy.
๐Ÿ‘ฉโ€โš•๏ธ Win for Operators
Rates that actually reflect documented costs. Predictable, transparent rate-setting. Ability to invest in workforce, pay competitive wages, and maintain facilities. No more arbitrary budget haircuts.
๐Ÿ‘ด Win for Residents
Better staffing ratios (adequate funding โ†’ competitive wages โ†’ filled positions). Better quality of care. More stable facilities โ€” fewer closures, fewer relocations. AHCA Feb 2026 proved: funding correlates with quality.
๐Ÿ’ต Win for Taxpayers
More federal dollars flowing into Idaho's economy ($32โ€“$82M in new federal funds depending on scenario). Reduced acute care costs ($14โ€“$37M in avoided hospitalizations). Preserved $1.53B in NF infrastructure.

๐ŸŽฏ The Core Argument for Legislators:

"The BAF makes Idaho's cost-based system a cost-based system in name only. Facilities document their costs. The state calculates what rates should be. Then the BAF discards that calculation to fit a budget number. Meanwhile, every dollar the BAF suppresses costs Idaho $2.33 in federal funds we'll never see. We're not asking for more state money โ€” we're asking Idaho to stop leaving federal money on the table. Replace the BAF with a transparent component system, and Idaho gets better care, more federal revenue, and the best nursing facility program in the Mountain West."

Idaho Code ยง56-101(21) (nursing facility inflation rate definition); ยง56-101(3) (bed-weighted median cost limits); ยง56-108 (property rental rate formula); KFF FMAP data (Idaho 70.01%); AHCA Feb 2026 (quality-funding correlation study)

Six Reforms: Building the Best Medicaid NF Program in America

Each reform includes the specific Idaho Code sections to amend, the model state program to reference, and the contact office at the model state for verification.

Reform A

Rate Methodology Reform โ€” Component-Based PDPM System

Replace the outdated cost-based/RUG-III methodology with a four-component rate:

  • Direct Care (55โ€“60%): Nursing salaries, supplies, food. PDPM case-mix adjusted, geographic wage indexed. Target: $145โ€“165/day
  • Indirect Care (25โ€“30%): Admin, activities, plant operations. No case-mix adjustment. Target: $65โ€“80/day
  • Capital (10โ€“12%): Replace ยง56-108 formula. Fair rental value with $25/day minimum. Target: $30โ€“45/day
  • Quality Incentive (5โ€“8%): Performance-based add-on. Target: $15โ€“30/day for top performers

Total target rate: $290โ€“350/day (still 40% below Oregon and North Dakota)

Mandatory annual rebasing using cost reports no older than 24 months.

๐Ÿ“ Model State: North Dakota โ€” Price-based RUG-IV, $586/day avg, 94% cost coverage, 5.5% assessment. Contact: ND Dept of Health & Human Services, Medical Services Division โ€” hhs.nd.gov
๐Ÿ“‹ Idaho Code Changes: Amend ยง56-101 (new definitions for PDPM, component rate, GAWI). Repeal ยง56-108 (property formula). New ยง56-108A (component methodology). New ยง56-108B (mandatory rebasing). Amend IDAPA 16.03.09 and 16.03.10.
Reform B

Provider Assessment Enhancement โ€” 5.5% of Net Patient Revenue

Idaho's SNF Assessment Act (Ch. 15) already authorizes up to 6%. Current collection is ~3โ€“4%. Increase to 5.5% (0.5% buffer below safe harbor).

Total NF net patient revenue (est.)$518 million
Current assessment (~3.9%)$20 million
New assessment at 5.5%$28.5 million
Federal match at 70.01% FMAP$66.5 million
Total program value$95.0 million
Net new federal funds$19.8 million

Fund allocation: 60% rate floor support ($17.1M) | 25% quality incentives ($7.1M) | 15% workforce development ($4.3M)

๐Ÿ“ Model States: North Dakota & Indiana โ€” Both use 5.5% assessment. IN generates ~$150M/yr for ~500 facilities. Contact: Indiana FSSA, Division of Aging โ€” in.gov/fssa | ND HHS โ€” hhs.nd.gov
๐Ÿ“‹ Idaho Code Changes: Amend ยง56-1505(2) (specify 5.5% minimum). Amend ยง56-1504(3) (add workforce fund, set allocation %). Amend ยง56-1505(3) (quarterly collection).
Reform C

Quality Scorecard โ€” 100-Point System, $15โ€“30/Day Bonuses

Transform Idaho's existing NFQPP into a meaningful quality incentive with transparent, measurable criteria:

  • Staffing (40 pts): Total nursing HPRD, RN HPRD, CNA retention rate, weekend staffing consistency (PBJ data)
  • Clinical Outcomes (30 pts): CMS Five-Star rating, hospitalization rate, antipsychotic use, pressure ulcers (CMS Quality Measures)
  • Survey Compliance (15 pts): Health deficiency score, complaint investigation outcomes (state survey data)
  • Resident/Family Satisfaction (15 pts): Standardized satisfaction surveys (e.g., My InnerView)

Payment tiers: Platinum (85โ€“100 pts) = $25โ€“30/day | Gold (70โ€“84) = $18โ€“24 | Silver (55โ€“69) = $10โ€“17 | Bronze (40โ€“54) = $5โ€“9 | Below 40 = $0

๐Ÿ“ Model State: Colorado HB23-1228 โ€” Requires quality improvement plans as condition of enhanced rates. Contact: CO Dept of Health Care Policy & Financing โ€” hcpf.colorado.gov | Bill text: leg.colorado.gov/bills/hb23-1228
๐Ÿ“‹ Idaho Code Changes: Amend ยง56-1504(3)(c) (expand VBP definition, specify scorecard domains, set bonus ranges). Idaho DHW Bureau of Long Term Care (Chris.Barrott@dhw.idaho.gov) currently administers NFQPP.
Reform D

Rate Floor โ€” No Facility Below 90% of Cost

Definition: The Medicaid per diem shall not be less than 90% of documented cost of care (audited cost report, inflation-adjusted to rate date).

Absolute minimum: $240/day (93% of current avg), adjusted annually by CPI-Medical.

Rate cut protections:

  • 90-day public comment period for any rate reduction
  • No rate cut during legislative recess (unless Governor declares fiscal emergency)
  • Access impact study required before any cut (per 42 USC ยง1396a(a)(30)(A))
  • Cuts exceeding 2% require JFAC review and approval
๐Ÿ“ Model State: Colorado HB23-1228 โ€” "Payment must not be less than 12% of total provider fee payments" (July 2024), rising to 15% (July 2026). Removed 3% annual GF cap. Signed May 30, 2023. Appropriated $30.5M state + $31.8M federal. Full text: leg.colorado.gov/bills/hb23-1228
๐Ÿ“‹ Idaho Code Changes: New ยง56-108C (rate floor definition, protections). Amend Title 56, Ch. 22 (require JFAC approval for cuts >2%).
Reform E

Workforce Development Fund โ€” $14.3M for CNA Pipeline

15% of enhanced assessment ($4.3M state) + federal match = $14.3M total annual fund.

  • CNA Training Pipeline (40%, $5.7M): Fund state-approved CNA programs at community colleges. Cover tuition + certification. Target: 500โ€“800 new CNAs/year. Require 24-month Idaho NF commitment.
  • LPN-to-RN Bridge (20%, $2.9M): Tuition assistance + loan forgiveness for nurses advancing while working in NFs. Target: 200โ€“300 students/year.
  • Wage Floor Support (30%, $4.3M): Supplements for facilities maintaining CNA wages at โ‰ฅ110% of county living wage (MIT Living Wage Calculator). Estimated target: $16.50โ€“19.00/hour.
  • Retention Bonuses (10%, $1.4M): Direct-to-employee: $1,000 at 12 months, $1,500 at 24 months, $2,500 at 36 months.
๐Ÿ“ Model State: Montana โ€” Workforce pipeline development was a key argument in securing 33% rate increase. MT DPHHS โ€” medicaidprovider.mt.gov
๐Ÿ“‹ Idaho Code Changes: Amend ยง56-1504(3) (add workforce development as authorized assessment fund use). Advisory committee with NF operators, CNA reps, Idaho Dept of Labor, Board of Nursing.
Reform F

Rate-Setting Process Reform โ€” No More Holiday Weekend Cuts

Mandatory annual calendar:

  • Oct 1: DHW publishes preliminary methodology parameters
  • Nov 1: Cost reports due
  • Jan 15: DHW publishes draft rates for each facility
  • Feb 1 โ€“ Mar 31: 60-day public comment + two public hearings (Boise + eastern Idaho)
  • Apr 15: Final rates published with comment responses
  • May 1: 30-day facility appeal window
  • Jun 1: Final rates confirmed
  • Jul 1: New rates effective

Establish Nursing Facility Rate Advisory Committee โ€” NF operators, direct care workers, resident advocates, IHCA, LeadingAge Idaho, DHW, rural NF representative. Quarterly meetings, published recommendations.

๐Ÿ“‹ Idaho Code Changes: New section in Title 56 establishing rate-setting calendar. Amend Ch. 22 (require JFAC annual NF rate adequacy report by Jan 31).

Financial Model: What It Actually Costs

Idaho's 70.01% FMAP = $2.33 federal for every $1 state. This is the most efficient healthcare investment Idaho can make.

Three Scenarios โ€” Net Cost to Idaho's General Fund

MetricModerate (+20%)Robust (+33%)Full Parity
Target avg rate$310/day$345/day$390/day (WA level)
Total spending increase$45.9M$77.2M$117.5M
State GF share of increase$13.8M$23.1M$35.2M
Provider assessment offsetโˆ’$8.5Mโˆ’$8.5Mโˆ’$8.5M
Net state GF cost$5.3M$14.6M$26.7M
Per Idaho resident/year$2.80$7.70$14.00
Federal funds generated$32.1M$54.1M$82.3M

The Moderate scenario costs Idaho's general fund $5.3 million per year โ€” and generates $32.1 million in new federal funds.

ROI from Reform

Financial model based on: 70 facilities, 73 avg beds, 80% occupancy, 60% Medicaid census, 895,345 annual Medicaid days, 70.01% FMAP

Implementation Timeline

1

Phase 1: Legislative Action (Janโ€“Jun 2027)

Introduce Idaho NF Sustainability & Quality Act. Enact assessment enhancement + rate floor + process reforms. Emergency rate stabilization: restore pre-September 2025 rates. Appropriate $2M for actuarial contract + IT.

2

Phase 2: Methodology Development (Jul 2027โ€“Jun 2028)

Contract actuarial firm (Myers & Stauffer/Milliman) for PDPM calibration study. Establish Rate Advisory Committee. Workforce Fund operational โ€” first CNA cohort funded. Quarterly assessment collection begins.

3

Phase 3: PDPM Transition Year 1 (Jul 2028โ€“Jun 2029)

50/50 blend: half new PDPM methodology + half legacy cost-based (Indiana model). Quality Scorecard dry run โ€” scoring with education, no payment impact. Monitor distributional impacts.

4

Phase 4: Full Implementation (Jul 2029โ€“Jun 2030)

Full PDPM component rates. Rate enhancement above budget-neutral (20โ€“33% increase). Quality bonuses active ($15โ€“30/day). Workforce Fund at full operation. Rate floor enforced.

5

Phase 5: Steady State (Jul 2030+)

Annual rebasing. Quality Scorecard refinement. JFAC annual rate adequacy report. Biannual PDPM calibration review. Ongoing neighboring-state comparison.

Model States โ€” Call Them

Every reform in this proposal is modeled on a real program in a real state. Here are the contacts.

$586
North Dakota โ€” Price-Based RUG-IV, 94% Cost Coverage
5.5% provider assessment (same as proposed for Idaho). Resident-specific billing. $38/day increase driven by cost reports. Annual rebase. Rate range $216โ€“$1,105.
๐Ÿ“ž ND Dept of Health & Human Services, Medical Services Division
hhs.nd.gov/healthcare/medicaid | 701-328-2321
$513
Oregon โ€” Tiered System (Basic/Complex/Vent)
Three tiers: Basic $568/day, Complex ~$765, Ventilator ~$1,284. Price-based prospective. Biennial rebase. 6% provider assessment. Quality metrics in CCO contracts.
๐Ÿ“ž Oregon DHS, Aging & People with Disabilities
oregon.gov/odhs | 503-945-5811
$292
Montana โ€” 33% Legislative Increase
Increased from $211 to $277+ through direct legislative action. Cost-based retained with rate enhancement. 6% assessment at federal safe harbor. Even post-increase, covers only ~60% of cost ($481/day actual).
๐Ÿ“ž Montana DPHHS, Senior & Long-Term Care Division
medicaidprovider.mt.gov | 406-444-4540
Rate schedule: SFY2026 PDF
$289
Colorado โ€” HB23-1228 Rate Floor
THE MODEL BILL. Rate floor: payment โ‰ฅ12% of provider fees (rising to 15%). Removed 3% GF cap. Required quality plans. Supplemental payments for high-Medicaid facilities. $62.3M combined appropriation.
๐Ÿ“ž CO Dept of Health Care Policy & Financing
hcpf.colorado.gov | 303-866-2993
Bill text: leg.colorado.gov/bills/hb23-1228 | Enacted May 30, 2023
$308
Indiana โ€” Phased PDPM Transition + 5.5% Assessment
Multi-year transition: 17% new / 83% legacy (2025), increasing annually. RUG-IV case-mix. 5.5% Quality Assessment Fee generates ~$150M/yr. All-payer cost coverage 114.66% (highest nationally). $3โ€“10/day quality add-on.
๐Ÿ“ž Indiana FSSA, Division of Aging
in.gov/fssa/da | 317-232-7020
$389
Washington โ€” RUGS Case-Mix + Legislative Support
RUGS-based case-mix prospective. Component rates (direct care, therapy, non-direct). Recent legislative increases for workforce. Rate range $220โ€“500. Annual rebase.
๐Ÿ“ž Washington HCA, Program Information for Providers
hca.wa.gov NF rates | 800-562-3022

Legal Framework โ€” Every Statute That Needs to Move

Idaho Code Amendments Required

SectionCurrentProposed Change
ยง56-101RUG-III definitionsAdd PDPM, component rate, GAWI, rate floor definitions
ยง56-108$9.24 property base (1985)Repeal. Replace with ยง56-108A component methodology
New ยง56-108Aโ€”Four-component PDPM rate methodology
New ยง56-108Bโ€”Mandatory annual rebasing requirement
New ยง56-108Cโ€”Rate floor at 90% of cost + cut protections
ยง56-1504(3)Assessment fund uses (VBP)Add workforce fund, set allocation percentages
ยง56-1505(2)Assessment rate (uncapped below 6%)Specify minimum 5.5% of net patient revenue
ยง56-1505(3)Annual collectionQuarterly collection
Ch. 22SPA legislative approvalAdd JFAC review for rate cuts >2%

IDAPA Rules Requiring Amendment

Federal Requirements

Idaho DHW Contact for NF Programs

Bureau of Long Term Care: Chris.Barrott@dhw.idaho.gov

Regional offices: Region I (208-769-1567), Region II (208-334-0940), Region III (208-455-7150), Region IV (208-334-0940), Region V (208-736-3024), Region VI (208-239-6260), Region VII (208-528-5750)

All Idaho Code citations verified at legislature.idaho.gov | IDAPA rules at adminrules.idaho.gov | Federal law at uscode.house.gov

The Ask

Idaho's 70+ nursing facilities employ 8,000+ workers and serve 4,500+ Medicaid residents daily. This is critical healthcare infrastructure that cannot be replaced once lost.

For $5.3 million in state general fund โ€” less than $3 per Idaho resident per year โ€” we can generate $32 million in federal funds, stabilize every nursing home in the state, and build the best Medicaid SNF program in the Mountain West.

Every dollar Idaho invests generates $2.33 from the federal government. No other investment in Idaho has that return.

Prepared by Idaho Health Care Association (IHCA) | August 2026 | All data cited with primary sources
Contact: Robert Vande Merwe, Executive Director • Luke Malek, Policy Director • (208) 343-9735

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๐Ÿ“Š

Infographics โ€” Visual Story

10-chapter visual narrative: The 82ยข Dollar, US Heatmap, Comparison Towers, Closure Crisis, Hidden Money waterfall, Provider Tax flow, Rate Growth Winners. Perfect for sharing or printing as handouts.

10 visual chapters | Animated charts | All data cited
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Operator Playbook

5 strategic plays every multi-state SNF operator should execute: Total Package PPD, State Scorecard, Cost Report Weaponization, PDPM Transition Wave, and Coalition Building. Each with step-by-step flow and panel talking points.

5 plays | Flow charts | Cited panel talking points
๐Ÿ”๏ธ

Idaho Medicaid Reform Proposal

"The Idaho Nursing Facility Sustainability & Quality Act" โ€” BAF analysis, 6 reform pillars, financial model (3 scenarios), implementation timeline, model state contacts with phone numbers, every Idaho Code section that needs to change.

6 reforms | BAF analysis | Idaho Code citations | Model state contacts
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Panel Q&A Prep

25 operator-focused questions with data-backed answers. Growth Strategy, Your States, Rate Mechanics, Advocacy, Industry Outlook. Every answer includes source citations.

25 Q&A pairs | 5 categories | All cited
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50-State Rate Table

All 50 states + DC with Medicaid SNF per diem rates, ranges, methodology, rebase frequency, and source citations.

51 jurisdictions | WPS GHA CY2025 + MN Rate Study
โš–๏ธ

Draft Legislative Bill

Formal Idaho bill text in proper legislative format โ€” 18 sections amending Title 56, Idaho Code. Component-based rate methodology, provider assessment to 5.5%, quality incentive program, workforce fund, rate floor, process reform. Ready for Legislative Services Office review.

18 sections | Full legal format | Statement of Purpose + Fiscal Note
โš™๏ธ

Technical Administration Guide

Complete algorithm specification for DHW rate analysts: 14-step rate calculation, all formulas, component ceilings, case-mix adjustment, quality scorecard rubric (15 measures, 100 points), two fully worked examples (urban Boise facility + rural Salmon facility), rate determination output format, IT systems requirements.

14-step algorithm | 2 worked examples | Quality rubric | IT specs
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Legislator Brief โ€” Plain Language

2-3 page plain-English explanation for every legislator: why this bill exists, what it does (6 reforms), how it works (3-year phase-in), benefits to constituents, providers, and the state, key numbers, and common questions answered.

3 pages | Plain English | Print-ready handout
๐Ÿ›ก๏ธ

Opposition Response Guide

15 anticipated objections with data-backed rebuttals: "too expensive," "it's a tax," "providers pocket it," "free market," "too complex," "CMS won't approve," and 9 more. Threat assessment, talking points, quick-reference rebuttal card for hearings.

15 objections | Data rebuttals | Quick-reference card | INTERNAL
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Committee Testimony Script

Complete prepared testimony for House Health & Welfare Committee: Robert Vande Merwe primary (18-22 min), Luke Malek policy witness, rural administrator, CNA, and family member supporting witnesses. Includes anticipated Q&A with prepared responses.

4 witnesses | 30+ minutes | Q&A prep | Customizable
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IHCA Board Resolution & Summary

Board executive summary with formal Resolution 2026-01 for endorsement vote. Board member action items by role, campaign overview, next steps. Ready for board meeting.

Resolution text | Board action items | Officer + region director assignments
๐Ÿ—บ๏ธ

Master Execution Playbook

THE master guide: 9-phase visual flowchart, week-by-week timeline with checkboxes, individual to-do lists for every person (Owen, Steve, Tim, Breanna, Jordan, Robert, Luke, Lindsay, Dana, Riley, all board), federal & state compliance checklists, campaign budget, risk register, success metrics, contact directory.

9 phases | 11 to-do lists | Checklists | Budget | Risks
๐Ÿ“ง

Complete Communications Package

Every letter, email, and template pre-written: DHW meeting request, CMS Region 10 pre-consultation, Governor's meeting request, DFM briefing, LSO cover letter, sponsor recruitment, 6 coalition support letters (AARP, IHA, IMA, etc.), grassroots kit, 3 op-ed drafts, press release, media kit.

11 sections | 20+ templates | All contacts | Print-ready
๐Ÿฉ

Governor's Executive Brief

2-page executive summary for Governor Little's office: fiscal impact, federal ROI, alignment with Governor's priorities (jobs, rural Idaho, fiscal responsibility), political landscape, specific asks, talking points.

2 pages | ROI-focused | Priority alignment | Talking points
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Complete Report โ€” Everything

All sections in one document: Overview, WOW Statements, Rates, Top 10, Adequacy, Programs, Levers, Infographics, Playbook, Q&A, Idaho Proposal, and Sources. Full research report with all citations.

All sections | 25+ sources | Print-optimized
Interactive Data Visualizations

50-State Medicaid SNF Rate Comparison

All 50 states + DC ranked by average Medicaid per diem. Source: WPS GHA CY2025; MN NF Rate Study 2025.

Payer Mix โ€” Patient Days

Source: MedPAC March 2026

Rate Methodology Distribution

Source: MACPAC NF Payment Policy

Regional Average Rates

Source: WPS GHA CY2025

All-Payer Margin Trajectory

Source: MedPAC March 2025/2026

Idaho vs. Neighboring States โ€” Rate & FMAP

Idaho has the highest FMAP (most federal leverage) but pays the lowest rate. The bars show Medicaid rate; the line shows federal match per $1 state investment.

Source: WPS GHA CY2025 (rates); KFF FMAP FY2026 (match rates)

Texas Total Package โ€” Base Rate vs. Effective Rate

Why the headline number is a lie. The total Medicaid package includes supplements most operators never see.

Source: WPS GHA CY2025; MACPAC NF Payment Policy

Rate Adequacy Spectrum โ€” Cost Coverage by State

Medicaid rate as percentage of estimated cost. Green = adequate. Red = crisis.

Source: MACPAC 2019 + updated estimates

Staffing Mandate: Cost vs. Funding

Source: CMS Final Rule; AHCA Analysis

Rate Growth Winners (2023-2026)

Source: Skilled Nursing News; state records

More data. More visuals. More ammunition.

Every State. One Chart.

All 50 states + DC sorted by Medicaid SNF per diem. Color = region. Source: WPS GHA CY2025; MN NF Rate Study 2025.

โ–  West โ–  Midwest โ–  Southeast โ–  Northeast
$
The Payer Mix Problem
63% of Days. 42% of Revenue.
That's Medicaid.
63%
of Patient Days
Medicaid
8%
of Patient Days
Medicare FFS
29%
of Patient Days
Private/Other/MA
-18%
Medicaid Margin
(below cost)
+25%
Medicare FFS Margin
2.1%
All-Payer Total Margin

Source: MedPAC March 2026 Report Ch.7; MedPAC July 2026 Data Book

8% of days subsidizing 63% of days. That's the business model.

The Cross-Subsidy: Medicare Profits Fund Medicaid Losses

MEDICARE FFS
+25%
margin on 8% of days
โ†’
MEDICAID
-18%
loss on 63% of days
โ†’
NET RESULT
2.1%
total margin (40% negative)

In any other industry, asking 8 profitable customers to subsidize 63 money-losing ones is called insolvency.

Source: MedPAC March 2026 Report Ch.7; ASPE/HHS 2024

The Price Gap
Same Bed. Same Care. $157 Apart.
$198
per day
Medicaid
$253
per day
Actual Cost
$315
per day
Private (Semi)
$355
per day
Private (Pvt Rm)

Source: ASPE/HHS 2024 ($198 Medicaid); SFNet/MedPAC ($253 cost); CareScout/Genworth 2025 ($315/$355 private pay)

Some states cover 94% of cost. Some cover 60%. Here's the full spectrum.

Rate Adequacy Spectrum: Cost Coverage by State

Medicaid rate as a percentage of estimated cost of care. Green = adequate. Red = crisis. Source: MACPAC 2019 + updated estimates.

96% COVERAGE
Minnesota
$373/day | Best nationally
94% COVERAGE
North Dakota
$586/day | Highest rate lower-48
92% COVERAGE
Wisconsin
$351/day | Early PDPM adopter
90% COVERAGE
Iowa
$236/day | Cost-based/RUG-III
86% COVERAGE
Ohio
$272/day | 5-year rebase
84% COVERAGE
National Avg
MACPAC baseline
81% COVERAGE
Michigan
$280/day | No case-mix grouper
75% COVERAGE
Wisconsin*
$351 all-payer coverage lowest MW
63-70% COVERAGE
IDAHO
$259/day | BAF-suppressed
60% COVERAGE
South Dakota
$278/day | Lowest documented
Margin Trajectory โ€” The Turnaround
States raised rates. Margins improved.
The data is clear.
-1.4%
2022
0.4%
2023
2.1%
2024

MedPAC credits this improvement directly to states raising Medicaid base rates.

46% โ†’ 40%
Facilities with negative margins
2023 โ†’ 2024
23% โ†’ 25%
Medicare FFS margin
2023 โ†’ 2026 (proj)

Source: MedPAC March 2025 & 2026 Reports to Congress; MedPAC July 2026 Data Book Sec.8

How America Sets Nursing Home Rates

Five fundamentally different approaches. Your strategy changes completely depending on which system your state uses.

19
Cost-Based
Your costs drive rates.
Report everything.
Lever: Cost reports
17
Hybrid
Cost + price elements.
Both levers matter.
Lever: Both
7
Case-Mix
Documentation quality
= payment level.
Lever: MDS coding
5
Price-Based
State sets the price.
Predictable but rigid.
Lever: Advocacy
3
Managed Care
MCOs negotiate rates.
Directed payments key.
Lever: Contracts

Source: MACPAC NF FFS Payment Policy Compendium; state Medicaid agencies. VA, RI transitioning RUGโ†’PDPM (2025). CT, KS transitioning (2026).

Idaho vs. Every Neighbor
Idaho pays less than every neighboring state
with a higher FMAP than all of them.
$259
Idaho
FMAP: 70.01%
$586
N. Dakota
FMAP: 54.23% โ†“
$513
Oregon
FMAP: 61.77% โ†“
$389
Washington
FMAP: 50.00% โ†“
$292
Montana
FMAP: 65.99% โ†“
$256
Wyoming
FMAP: 50.00% โ†“

Idaho has a HIGHER FMAP than every neighbor (โ†“) โ€” gets MORE federal match per dollar โ€” yet pays THE LEAST.

Source: WPS GHA CY2025 (rates); KFF FMAP FY2026 (match rates)

The Proof
Fund Quality. Get Quality.
The data is unambiguous.
AHCA February 2026 Study
"Medicaid funding is directly correlated with nursing home quality." States that increased rates saw measurable quality improvement across staffing ratios, star ratings, and hospitalization rates.
MedPAC March 2026
All-payer total margin improved from -1.4% (2022) to 2.1% (2024) โ€” "driven primarily by aggregate increases in Medicaid base rates." States that raised rates stabilized facilities.
Montana: The Case Study
33% rate increase over 2 fiscal years. Workforce stabilization followed. CNA vacancy rates improved. Facility closure risk reduced. Access preserved in rural communities.
The Inverse Is Also True
774 facility closures since 2020. 62,567 beds lost. 28,421 residents displaced. States that cut rates or froze them saw accelerated closures and quality decline. Defunding doesn't save money โ€” it shifts costs.

Sources: AHCA Feb 2026 press release; MedPAC March 2026 Ch.7; AHCA 2024 Access Report; Skilled Nursing News (MT)

๐Ÿ’ฐ The FMAP Cheat Sheet: What $1 Buys in Each State

FMAP = Federal Medical Assistance Percentage. Higher FMAP = more federal money per state dollar. Idaho's 70.01% is among the highest.

IDAHO
$2.33
federal per $1 state
FMAP: 70.01%
UTAH
$2.35
FMAP: 70.35%
MONTANA
$1.94
FMAP: 65.99%
OREGON
$1.62
FMAP: 61.77%
N. DAKOTA
$1.18
FMAP: 54.23%
WASHINGTON
$1.00
FMAP: 50.00%

Idaho gets $2.33 for every $1 invested. North Dakota gets $1.18. Yet North Dakota pays $586/day and Idaho pays $259.