Q&A with Nissa Shaffi of Alliance of Community Health Plans

Q. Thank you so much for taking the time to share the work of ACHP. But before we start, Nissa, can you tell us a little bit about you and your journey to the organization?

Absolutely. Thanks, Fortuna, for this opportunity to share the great work of ACHP members in the Medicaid space. I originally got my start in healthcare at Inova Health System, a large hospital system in Northern Virginia. I worked in emergency patient services and advocacy, which gave me my first exposure to disparities and access issues prevalent in my community.

I also led a patient advocacy group at the Loudoun Free Clinic, where I saw firsthand how health policy decisions impact individuals, and that drove me to pursue a career in shaping health policy. I held internships at the Library of Congress, working on reports commissioned by Members of Congress related to mental health parity and maternal health, and I gained nonprofit experience at or

ganizations that focus on access to mental health services and public health.

Prior to joining ACHP, I was at the National Consumers League, the nation's oldest consumer watchdog organization. I led campaigns on maternal health, medication adherence, counterfeit drugs and vaccine confidence. I’ve always been driven by a desire to address disparities, and now at ACHP, I get to shape the organization’s Medicaid, dual-eligible, and ACA marketplace portfolios, which touch on the most vulnerable populations in our healthcare system.

Q. ACHP represents a wide range of nonprofit community health plans. How does ACHP’s advocacy work differentiate itself from other organizations in the health policy space?

ACHP’s advocacy work is unique, because we integrate three key areas: data analytics, clinical innovation, and federal advocacy.  Our member companies are provider-aligned, community-focused health plans delivering exceptional care coordination and patient satisfaction. This commitment has positioned them as top-performing nonprofit health plans nationally.

Q. Given that there are so many different plans with varying priorities, how does ACHP work with its member plans to identify the main advocacy priorities?

ACHP is a highly collaborative organization. Our weekly membership meetings offer a chance to discuss policy priorities, covering everything from legislation to regulation. Additionally, we organize dedicated workgroups on specific topics, such as dual-eligibles, Medicare Advantage, or drug pricing. These workgroups are composed of subject matter experts who refine our policy positions and ensure we’re delivering the most impact across our advocacy efforts.

Q. How does ACHP decide which topics or themes to prioritize within its advocacy efforts?

We base it on the potential impact to beneficiaries and the health plans that serve them, as well as the potential for certain proposals to affect care delivery overall. For example, our data team focuses heavily on quality analytics, while our clinical team works on grant-funded projects in areas like maternal health and diabetes. Our advocacy team, meanwhile, focuses on regulations and legislation. Each group contributes their expertise to ensure we are aligned across the organization on what we’re promoting and advocating for.

Q. What major policy changes would ACHP like to see from CMS and states to improve Medicaid, from capitation rate changes to health equity and value-based frameworks?

One of the biggest issues facing many of our members right now are inadequate Medicaid capitation rates, so we’re actively supporting their respective state advocacy efforts, while also lifting the issue up with the Biden administration to adjust the rates to reflect current patient acuity and utilization trends. 

During the COVID-19 pandemic, Medicaid enrollment reached 95 million due to coverage protections. Now, after the unwinding, 25 million people lost coverage, many of whom are healthier individuals who balanced out the risk pool. The remaining enrollees tend to have higher utilization and are sicker than anticipated by states, but the capitation rates set by states don’t reflect this reality. States are using data from the height of the pandemic, which do not accurately reflect current patient health and utilization trends. We’re urging CMS and HHS to request states to adjust those rates going into 2025, and if possible, retroactively for 2024, using current patient data.

Q. In terms of value-based care and health equity, are there any specific initiatives or policies ACHP is pushing forward?

Absolutely. We were awarded a PCORI grant to explore the impact of toxic stress on black maternal health outcomes. Last year, we held a roundtable bringing together black maternal health experts, including providers and researchers, to develop a research agenda, informed by black women, for black women. This is a unique effort in the payer space, and we’re so proud that ACHP is leading the charge in getting to the core issues leading to the currently dismal black maternal health outcomes. We are also strong supporters of state 1115 waivers to address social determinants of health (SDOH). We’re advocating for public program alignment so that when someone applies for Medicaid, the system also assesses eligibility for other supports like TANF or SNAP. Streamlining these processes ensures more efficient referrals and a more holistic approach to patient care.

‍Q. The Medicaid unwinding was a significant event for your member plans. How did the temporary expansion of Medicaid during the pandemic impact access to care, and how did ACHP members ensure continuity during the unwinding?

The pandemic expanded access to preventive services and improved care continuity. During the unwinding, our members were proactive in ensuring patients renewed their coverage on time or transitioned to other forms of coverage. Many plans stood up dedicated call centers with live support and language capabilities to help enrollees assess their eligibility for Medicaid or other coverage options. These call centers also helped direct beneficiaries to critical SDOH referrals for food, housing, and other supports – enhancing and streamlining the overall eligibility process.

‍Q. Financial stability is a major concern for health plans, particularly given the pressures on workforce and rates. How is ACHP helping plans maintain financial stability, and can you give examples of efforts in rural communities?

One area we’re focusing on is ACA risk adjustment. Community health plans, especially in rural areas, need support to compete fairly against larger plans with greater data capabilities. We’re advocating for CMS to finalize recommendations made a few years ago to recalibrate risk adjustment models. We’re also pushing for risk adjustment in the ACA to be more akin to Medicare Advantage, where patients’ risk profiles follow them if they transition from one plan to another. 

One way to ensure that is via data sharing, where ACA health plans would be able to access data on existing enrollees who switch from one plan to another. This way, health plans are not operating from a blank slate and can price their products more accurately, translating to more marketplace stability for both health plans and enrollees.

Q. ACHP has been highlighting various health equity efforts by its members. How do you identify and aggregate these initiatives, and are there efforts to make them actionable across other member plans?

We actively share best practices across our organization. For example, UPMC has an incredible program that hires its Medicaid beneficiaries into the UPMC workforce, helping to disrupt the cycle of poverty. Kaiser Permanente’s “Food is Medicine Center of Excellence” is another example, where the plan has established a central hub, integrating food and nutrition interventions with care delivery to promote prevention and treatment of diet-related illnesses. To help capture all this great work, we’re working on a data aggregation project to assess and share how our plans are performing across different health equity initiatives. The project is still in the development phase and will be operational in the next couple of years.

Q. ACHP is supporting legislation to promote care coordination for dual-eligibles. With so many proposed CMS rules coming between now and 2026, what are some urgent considerations for your member plans, and how is ACHP addressing them?

One piece of legislation we’re actively supporting is the DUALS Act, led by Senator Cassidy. We’re also actively working with our members as they implement requirements from the 2023 Medicare Advantage and Part D rule, which requires exclusive alignment of Medicare and Medicaid services. We’re focusing heavily on integration for dually eligible individuals, because it has the biggest impact on our members, especially in states with Medicaid carve-outs. 

We’re advocating for passive enrollment of consumers into highly rated integrated plans, with their consent, to enhance care coordination and improve the patient experience. We’re also looking into implications of the loss of managed Medicaid contracts on Duals integration overall. There are other policy developments such as the Health Equity Index, which will have a significant impact on health plans serving Duals.

Q. Finally, how do you see Medicaid policy evolving over the next few years, particularly in the context of managed care and the new administration?

Medicaid, particularly through 1115 waivers, has been a catalyst for healthcare innovation. Significant progress has been made in addressing SDOH. To sustain this momentum, it's crucial to leverage data to demonstrate the economic and health benefits of these interventions.

The incoming administration may overturn or delay recently finalized Medicaid rules on eligibility, managed care, and fee-for-service, as well as introduce changes to Medicaid financing via eligibility criteria, potentially impacting coverage access. One bright spot is that we may see an increased adoption of value-based care within managed care, particularly in mental health and telehealth, which could drive innovation, improve health outcomes, and control costs.