Comment on CMS-2026-1916-0001
Richmond University Medical CenterSupportBusiness
Summary: Richmond University Medical Center, a nonprofit safety-net hospital, supports the proposed rule but requests a specific clarification regarding the transfer of "grandfathered" payments. They argue that CMS should allow a state to transfer a provider-attributable portion of these payments to a successor provider following a bona fide merger or acquisition to prevent the loss of critical funding for safety-net services.
Richmond University Medical Center appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services' proposed rule implementing and interpreting Section 71116 of Public Law 119-21 governing Medicaid managed care state directed payments. Please see our attached comment letter.