Comment on CMS-2026-1916-0001
Duke-Margolis Institute for Health PolicyOpposeAcademic
Summary: The Duke-Margolis Institute for Health Policy at Duke University opposes the proposed rule because it could limit states' ability to implement effective value-based payment (VBP) arrangements in Medicaid. They argue that the proposed per-service payment limits are incompatible with VBP models and recommend establishing an explicit pathway to exempt CMS-approved VBP models from these limits.
Please see attached.
This submission is intended to entirely replace and supersede the previously submitted comment uploaded under Comment Tracking Number: mrv-6yg5-043x. The prior version was uploaded inadvertently.