CMS’s September guidance split the medically frail Medicaid exemption into three tiers. Only tier three requires a licensed clinician. That tier is still unserved.
Nebraska went live May 1. Montana launched July 1. North Carolina and Utah barred self-attestation in year one. The documentation wave is real and already started.
Fortuna Health owns the navigation layer: 21 states, 25 million-plus Medicaid lives, a16z money, a hospital channel through Cedar. Building a second navigator is a price war with free.
The business that exists is the clinical layer behind Fortuna: a state-by-state rules engine, licensed clinicians for tier three packets, and a reinstatement shop. The missing piece is still a company.
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