The AAMC submitted comments to the Centers for Medicare & Medicaid Services (CMS) opposing provisions of a May 20 proposed rule related to Medicaid managed care state directed payments (SDPs) and fee-for-service (FFS) supplemental payments [refer to Washington Highlights, May 22]. In implementing Section 71116 of the One Big Beautiful Bill Act (OBBBA, P.L. 119-21, PDF), the comments note, the CMS has issued proposals that go beyond the statutory framework established in the statute. The AAMC outlined concerns about the rule’s negative impacts on access to care and urged the agency to withdraw the proposed provisions that are not statutorily required.
The AAMC’s comments called on the CMS to preserve the ability of states to target Medicaid FFS payments to physicians and practitioners, including physicians at academic health systems and safety-net hospitals, as these proposed changes go beyond the statutory framework established in the OBBBA. The comments also urged the agency to limit SDP changes and restrictions to the provisions of OBBBA and allow states flexibility to target payments to providers with historically low payment rates and that treat disproportionate numbers of Medicaid patients. Further, comments asked the CMS to reevaluate the calculation of the Medicare rate limit to allow for aggregate Medicare payment limits inclusive of Medicare payment adjustments, similar to CMS’ methodology to calculate upper payment limit payments. Lastly, the AAMC urged the CMS to work with states by allowing for alternative phase-down approaches based on a state’s circumstances to ensure an appropriate off-ramp for grandfathered SDPs.