Comment on CMS-2026-1916-0001

Summary: BayCare Health System, a large academic healthcare system in Florida, opposes the proposed rule because it exceeds the scope of Congressional intent by imposing more stringent payment limits and faster phase-down methodologies for State Directed Payments (SDPs). They argue these reductions will lead to service losses, hospital closures, and increased administrative burdens, and they urge CMS to align the rule with the statutory framework.