Comment on CMS-2026-1916-0001

Summary: The National Association of Accountable Care Organizations (NAACOS) opposes the proposed rule, arguing that the requirements for validation methodologies and payment limits on value-based payment (VBP) arrangements will hinder the growth of Medicaid alternative payment models. They advocate for a model that focuses on lowering total overall costs and incentivizing providers to join APMs rather than focusing on unit-based payment limits.