Comment on CMS-2026-1916-0001

Summary: Okeene Municipal Hospital, a rural Critical Access Hospital, opposes the proposed rule's uniform phase-down timeline for Medicaid State Directed Payments (SDP), arguing it will cause disproportionate financial harm to rural facilities. They request state authority to differentiate phase-down sequencing by facility class, clearer definitions for cost-reconciliation exemptions for low-volume providers, and a standardized template for actuarial-certification requirements.