Whenever risk-based, capitated models are used, payment structures must encourage appropriate utilization of care and reward the provision of preventive care, intensive transition supports, and home and community-based services.  A  brief from the Kaiser Family Foundation, People with Disabilities and Medicaid Managed Care: Key Issues to Consider, states that evidence of significant unmet need among Medicaid beneficiaries with disabilities in fee-for-service suggests that FFS utilization may not provide a sound basis for setting capitation rates.

Comparisons to fee for service utilization also become increasingly problematic, or impossible, in a service area where managed care is dominant or exclusive.