Comment on CMS-2026-1916-0001

As a primary care pediatrician working in Pittsburgh for the past 14 years, I have had the honor and pleasure of caring for young patients, whether they are sick, injured, or healthy and simply coming in for their check-ups. Our clinic measures growth and development during well child care visits and provides immunizations to protect against deadly infectious diseases like pneumonia and meningitis. We screen for hearing and vision problems and mental health disorders like autism, anxiety and depression, providing support early on before health conditions become more severe. And when needed we refer to pediatric subspecialists to provide care for our patients outside our areas of expertise. Because children are obviously too young to pay for these services themselves, they rely on coverage paid for by private health insurance plans, often through their parents’ employers, or by public insurance programs like Medicaid and Children’s Health Insurance Program (CHIP). Here in Pennsylvania more than one million children receive health insurance coverage through Medicaid. Unfortunately, children are at risk of losing access to vital health services. The Centers for Medicare and Medicaid Services (CMS) have proposed a rule that would reduce the payment rate on State Directed Payments (SDPs) and fee-for-service (FFS) payments. These payments are what keep many hospitals and clinics like mine open, caring for patients and ensuring access to healthcare for millions of children and adults alike. Many healthcare workers and patients know Medicaid reimburses significantly less than Medicare and private insurance. SDPs were designed to bridge this disparity, ordering managed care organizations (MCOs) to increase reimbursement rates and allowing providers to care for patients insured by Medicaid. This rule change placing limits on payments puts access to healthcare for patients in jeopardy. Last year when the One Big Beautiful Bill Act was signed into law, billions of dollars were cut from Medicaid ($911 billion over the next 10 years to be exact, according to the Kaiser Family Foundation). This CMS rule change expands these cuts even further, and will impact the most vulnerable groups including children, pregnant mothers and the elderly. A report last year from the Pennsylvania Health Access Network (PHAN) found that 1 in 5 hospitals in Pennsylvania (47 total) were at moderate to significant risk of financial instability as a result of changes to Medicaid funding or patient eligibility; 30 of these hospitals were in urban areas and 17 in rural areas, from UPMC Magee Women’s Hospital in Pittsburgh, where most of my patients are born, to St. Christopher’s Hospital for Children in Philadelphia. The proposed CMS rule heightens their risk even further. Americans are already feeling the pain of high inflation and expensive groceries, gas and utilities. They don’t need any more stress from further cuts to their health insurance, especially when the country is suffering outbreaks of deadly diseases like measles from declining immunization rates. The Pennsylvania Department of Health has reported over 100 cases of measles this year, a disease that had previously been eliminated from the U.S. Pediatricians, the American Academy of Pediatrics (AAP) and the Association of American Medical Colleges (AAMC) are alerting the public about the harms this rule change will cause. During difficult times, we should be strengthening insurance coverage for our most vulnerable, not cutting their support. By doing so, we can address problems earlier on before they become more complicated and expensive. We now have so many new tools at our disposal to promote health and wellness for current and future generations, from powerful AI technologies that improve diagnostics and reduce administrative burden, to lifesaving vaccines like nirsevimab which protect babies from severe illness from Respiratory Syncytial Virus (RSV). We should invest in our children's health, they are worth every dollar.