Brian Blase, Ph.D., is the President of Paragon Health Institute. Brian was Special Assistant to the President for Economic Policy at the White House’s National Economic Council (NEC) from 2017-2019, where he coordinated the development and execution of numerous health policies and advised the President, NEC director, and senior officials. After leaving the White House, Brian founded Blase Policy Strategies and served as its CEO.
Medicaid Money Laundering Apparatus is Driving Medicaid Rates Way Above Medicare
Key Takeaways
- Provider taxes and other financing mechanisms allow states to draw down massive federal funds with minimal real state contributions.
- States increasingly return these funds to hospitals and other providers through state-directed payments via managed care plans.
- States are increasingly making these payments up to average commercial rates.
- Commercial rates are, on average, more than 2.5 times higher than Medicare rates.
The Medicaid Money Laundering Scheme
More than 80% of voters support capping Medicaid payment rates at no more than Medicare rates.

Providers, particularly hospitals, frequently help develop these schemes because states guarantee them higher payment rates. Over the past few years, Medicaid payments to hospitals through managed care plans have soared. In many states, these payments now approach or even equal average commercial rates.
On average, commercial rates for hospital services are more than 2.5 times higher than Medicare rates. This payment disparity incentivizes providers to prioritize Medicaid patients over Medicare recipients, which not only undermines seniors’ access to care but also drives up federal taxpayer costs.
A state-directed payment (SDP) is a mechanism through which states instruct managed care organizations to make targeted payments to providers for specific services or outcomes. These payments are frequently funded through mechanisms like provider taxes. This Medicaid money laundering cycle not only undermines federal budget integrity but also distorts provider incentives, causing providers to prioritize higher-paying Medicaid patients over Medicare recipients.
Currently, Medicaid fee-for-service is subject to an upper payment limit (UPL) that caps federal reimbursement at Medicare rates. However, no such limit exists in Medicaid managed care, where state-directed payments can significantly exceed Medicare rates. To correct this imbalance, Congress should establish a parallel UPL for managed care services. This reform would align Medicaid payments with Medicare rates, eliminating financial incentives that prioritize Medicaid patients over Medicare beneficiaries. States could still choose to pay providers higher rates using state-only funds but would not receive federal matching dollars for payments exceeding the UPL.
For more information on the Medicaid money laundering schemes and Paragon’s recommendations to curb them, see our recent report, Addressing Medicaid Money Laundering: The Lack of Integrity with Medicaid Financing and the Need for Reform.
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