Comment on CMS-2026-1916-0001
National Association of Pediatric Nurse PractitionersOpposeTrade association
Summary: The National Association of Pediatric Nurse Practitioners (NAPNAP) opposes the proposed rule, arguing that it imposes restrictive Medicare-based payment limits that are structurally mismatched to pediatric care. They contend that the rule will lead to lower reimbursements for pediatric nurse practitioners, potentially causing workforce shortages and reducing access to care for children who depend on Medicaid and CHIP.
On behalf of more than 7,500 pediatric nurse practitioners (PNPs) and pediatric-focused advanced practice registered nurses (APRNs) committed to providing the best possible health care to children, the National Association of Pediatric Nurse Practitioners (NAPNAP) is grateful for the opportunity to share its comments on the May 22, 2026, proposed rule, “Medicaid Program; Medicaid Managed Care State Directed Payments and Medicaid Fee-for-Service Targeted Medicaid Practitioner Payments,” CMS-2449-P; 91 Fed. Reg. 30400-30466).
We have serious concerns about the impact this proposed rule would have on our members’ ability to provide critically important care for more than 35 million children and adolescents that depend on Medicaid and the Children’s Health Insurance Program (CHIP) and for all their patients as lower reimbursements affect their practices. Policies that make it more difficult for states to support providers and patients threaten access to care for the communities that have the greatest need.