Comment on CMS-2026-1916-0001
Families USAOpposeAdvocacy
Summary: Families USA opposes the proposed rule because it exceeds CMS' statutory authority by extending payment limitations to providers and payment types not specified in Public Law 119-21. The organization argues that the rigid caps and restrictions on state-directed payments (SDPs) will undermine state flexibility, reduce patient access to care, and shift costs from the federal government to the states. They recommend that CMS withdraw the overreaching portions of the rule and instead establish a Medicare reimbursement floor while allowing states the flexibility to supplement rates above that benchmark when necessary.
We thank you for the opportunity to comment on CMS’ proposed rule implementing Public Law 119-21 §71116 and expanding the state-directed payment limits set by Congress to Medicaid payments across the system in Medicaid managed care and Medicaid fee-for-service. For questions or comments regarding the recommendations in this letter, please contact Mary-Beth Malcarney, Senior Advisor on Medicaid Policy, Families USA at mmalcarney@familiesusa.org. Please see the attached file.