Comment on CMS-2026-1916-0001

Summary: Michigan Medicine, a major academic medical center, opposes the proposed CMS methodologies for establishing Medicare-based payment limits for State Directed Payments (SDPs) due to administrative complexity and potential underpayment of services. They specifically advocate for aggregate provider-level calculations, the preservation of Separate Payment Terms (SPTs), and the continued use of uniform increases to ensure adequate reimbursement and access to care.