CMS Proposes Medicaid Indirect Hold Harmless Threshold

The Centers for Medicare & Medicaid Services released a proposed rule implementing Section 71115 of H.R. 1, known as the Working Families Tax Cut Act. The proposed rule would implement new hold harmless requirements and codify the statutory limits of Section 71115.

As proposed, new indirect hold harmless thresholds for health care-related taxes would generally be based on taxes that were enacted and imposed as of July 4, 2025. The Missouri Hospital Association published an issue brief with additional information. Comments about the proposed rule are due Monday, Sept. 21.