Medicaid Program: Medicaid Managed Care State Directed Payments and Medicaid Fee-for-Service Targeted Medicaid Practitioner Payments
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- Title
- Medicaid Program: Medicaid Managed Care State Directed Payments and Medicaid Fee-for-Service Targeted Medicaid Practitioner Payments
- Posted
- May 22, 2026
- Comment period
- May 22, 2026 – Jul 22, 2026
- FR Doc
- 2026-10292
- CFR
- 42 CFR Parts 438 and 447
- Topics
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Stance breakdown
Who commented
Breakdown by commenter type.
Comments over time
Weekly arrivals, stacked by stance.
Support × commenter type
How each type splits across stance.
Issues raised
The docket's canonical issues. Select one to browse its comments.
Position map
Who stands where on each issue?
Every non-silent position is backed by an excerpt from the comment.
Issues shown
Uncheck an issue to choose another.
| Organization | Gemt program funding | Fire-based ems exemptions | Medicaid reimbursement rates | Administrative burden and readiness | Medicaid reimbursement rate reductions |
|---|---|---|---|---|---|
Academy of International Mobile Healthcare Integration Trade associationOppose The Academy of International Mobile Healthcare Integration (AIMHI) opposes the proposed rule because it would cap supple | · | · | · | ||
Ada County Paramedics GovernmentOppose Ada County Paramedics, a county-based EMS taxing district, opposes the proposed rule that would limit Ground Emergency M | · | · | · | ||
Allen Parish Ambulance BusinessOppose Marna Istre, Executive Director of Allen Parish Ambulance, opposes the proposed rule because it sets a Medicaid payment | · | · | · | ||
Ambulance District Asso of Missouri, Missouri Ambulance Assco, Missouri EMS Asso and the Missouri Fire Chiefs Assoc Trade associationOppose A coalition of Missouri EMS and fire service associations opposes the proposed limitation on Ground Emergency Medical Tr | · | · | · | ||
Arbor Health BusinessOppose Arbor Health, a rural healthcare system, opposes the proposed rule's calculation of Medicare rates at the service and ho | · | · | · | · | · |
Aurora Fire Department GovernmentOppose Kevin Nickel, Interim Fire Chief of the Aurora Fire Department, opposes the proposed rule because it would limit Ground | · | · | |||
Beecher Fire Protection District GovernmentOppose The Beecher Fire Protection District, a fire-based EMS organization, opposes the proposed rule to limit Ground Emergency | · | · | |||
Bennington Rescue Squad AdvocacyOppose The Bennington Rescue Squad, an emergency medical services provider, opposes the proposed rule because it would cap Medi | · | · | · | · | |
Burney Fire Protection District GovernmentOppose The Burney Fire Protection District opposes the proposed rule capping Ground Emergency Medical Transportation (GEMT) sup | · | · | · | ||
California Fire Chief Associations Trade associationOppose The California Fire Chiefs Association opposes the proposed rule capping Ground Emergency Medical Transportation (GEMT) | · | · | · | ||
California Professional Firefighters UnionOppose The California Professional Firefighters (CPF), representing over 38,000 personnel, opposes the proposal to cap Ground E | · | · | |||
Cascade Rural Fire Protection District GovernmentOppose The Cascade Rural Fire Protection District, a governmental fire-based EMS service, opposes the proposed rule that would | · | · | · | ||
Cathedral City Fire & EMS GovernmentOppose Michael Contreras, Fire Chief of Cathedral City Fire & EMS, opposes the proposed rule because capping Ground Emergency M | · | · | · | ||
Cedarburg Fire Department GovernmentOppose The Cedarburg Fire Department opposes the proposed federal restrictions and payment caps on Ground Emergency Medical Tra | · | · | · | ||
CENCAL Fire & EMS Authority GovernmentOppose Lenard Gutierrez, Executive Director of CENCAL Fire & EMS Authority, opposes the proposed rule capping Ground Emergency | · | · | |||
City of Alameda Fire Department GovernmentOppose The City of Alameda Fire Department opposes the proposed rule capping Ground Emergency Medical Transportation (GEMT) sup | · | · | · | ||
City of Albany Fire Department GovernmentOppose Chris LaBelle, Fire Chief of the City of Albany Fire Department, opposes the proposed rule because it would limit State | · | · | · | · | · |
City of Berkeley Fire Department GovernmentOppose The City of Berkeley Fire Department opposes the proposed limitation on Ground Emergency Medical Transportation (GEMT) s | · | · | · | ||
City of Carlsbad GovernmentOppose Nate Pearson, representing the City of Carlsbad Fire Department, opposes the proposed rule capping Ground Emergency Medi | · | · | · | ||
City of Des Plaines Fire Department GovernmentOppose Matthew Matzl, Fire Chief of the City of Des Plaines Fire Department, opposes the proposed rule to cap Ground Emergency | · | · | |||
City of Dinuba Fire Department GovernmentOppose Greg Chastain, Fire Chief of the City of Dinuba Fire Department, opposes the proposed reimbursement caps for governmenta | · | · | · | ||
City of Fullerton - Fire Department GovernmentOppose The City of Fullerton Fire Department opposes the proposed application of Medicare-based payment limits to governmental | · | · | · | ||
City of Glendale Fire Department GovernmentOppose Jeff Brooks, Fire Chief of the City of Glendale Fire Department, opposes the proposed rule capping Ground Emergency Medi | · | · | · | ||
City of Gonzales Fire Department GovernmentOppose Chief Preston Landry of the City of Gonzales Fire Department opposes the proposed rule because it sets a Medicaid paymen | · | · | |||
City of Indian Wells GovernmentOppose The City of Indian Wells opposes the proposed rule because it would cap Ground Emergency Medical Transportation (GEMT) p | · | · | · | ||
City of Naperville GovernmentOppose The Mayor of Naperville, Illinois, is requesting that CMS withdraw or revise the proposed limitation on Ground Emergency | · | · | · | ||
City of Petaluma Fire Department GovernmentOppose Jeff Schach, Fire Chief of the City of Petaluma Fire Department, opposes the proposed rule because it would cap Ground E | · | · | |||
City of San José GovernmentOppose The City of San José opposes the proposed rule because it would cap supplemental payments for ground emergency medical t | · | · | |||
City of South Pasadena Fire Department GovernmentOppose The City of South Pasadena Fire Department opposes the proposed rule capping Ground Emergency Medical Transportation sup | · | · | · | ||
City of Sterling Heights Fire Department GovernmentOppose The City of Sterling Heights Fire Department opposes the proposed limitation on Ground Emergency Medical Transportation | · | · | · | ||
Colorado Springs Fire Department GovernmentSupport Randy Royal, Fire Chief of the Colorado Springs Fire Department, urges CMS to protect the Ground Emergency Medical Trans | · | · | · | ||
Community Behavioral Health Association of Maryland AdvocacyOppose The Community Behavioral Health Association of Maryland (CBH) opposes the proposed rule because it extends Medicare-base | · | · | · | · | · |
Coulee Medical Center BusinessOppose Coulee Medical Center, a rural Critical Access Hospital, opposes the proposed rule because it threatens the financial vi | · | · | · | · | · |
Crested Butte Fire Protection District GovernmentSupport Sean Caffrey, representing the Crested Butte Fire Protection District, urges CMS to exempt governmental, volunteer, and | · | · | |||
East Baton Rouge Parish Department of Emergency Medical Services (EBREMS) GovernmentOppose The East Baton Rouge Parish Department of Emergency Medical Services (EBREMS) opposes the proposed rule because it sets | · | · | · | · | |
Emergency Medical Services Association of Colorado Trade associationSupport The Emergency Medical Services Association of Colorado (EMSAC) supports the proposed rule's intent to preserve cost-reco | · | · | · | ||
Essentia Health BusinessOppose Essentia Health, a healthcare organization with 15,000 employees, opposes the proposed rule because it exceeds the statu | · | · | · | ||
Falcon Fire Protection District GovernmentSupport The Falcon Fire Protection District, a governmental fire-based EMS agency, argues that the proposed rule could negativel | · | · | |||
Fayette County Ambulance BusinessOppose Fayette County Ambulance opposes the proposed rule, arguing that it would weaken Alabama's successful ambulance suppleme | · | · | · | ||
Fire Districts Association of California Trade associationOppose The Fire Districts Association of California opposes the proposed rule capping Ground Emergency Medical Transportation ( | · | · | |||
fire-based EMS organization GovernmentOppose The commenter, an Assistant Fire Chief of a fire-based EMS organization, opposes the proposed rule because it may restri | · | · | · | ||
Florida Behavioral Health Association AdvocacyOppose The Florida Behavioral Health Association (FBHA) opposes the proposed rule because it would impose payment caps on menta | · | · | · | · | · |
Foothill Fire Chiefs Association Trade associationOppose The Foothill Fire Chiefs Association opposes the proposed cap on Ground Emergency Medical Transportation (GEMT) suppleme | · | · | · | ||
Fremont Fire Department GovernmentOppose Zoraida Diaz, Fire Chief of the Fremont Fire Department, opposes the proposed rule because capping Ground Emergency Medi | · | · | · | ||
Glen Ellyn Volunteer Fire Co. GovernmentOppose The Fire Chief of the Glen Ellyn Volunteer Fire Co. | · | · | |||
Glendale Firefighters Association Local 776 UnionOppose Ara Zakarian, President of the Glendale Firefighters Association Local 776, opposes the proposed rule because it would c | · | · | |||
IAFC (International Association of Fire Chiefs) Trade associationOppose The commenter, representing the International Association of Fire Chiefs (IAFC), opposes the proposed payment limits for | · | · | · | ||
Imagine Pediatrics AdvocacySupport Imagine Pediatrics supports CMS's efforts to strengthen oversight and transparency of State Directed Payments in Medicai | · | · | · | · | · |
Indiana Council of Community Mental Health Centers Trade associationOppose The Indiana Council of Community Mental Health Centers (ICCMHC) opposes the proposed rule because it would impose paymen | · | · | · | · | · |
Joliet Fire Department GovernmentOppose The City of Joliet Fire Department opposes the proposed rule to limit Ground Emergency Medical Transportation (GEMT) sup | · | · | · | ||
Kit Carson County Ambulance Service GovernmentOppose Shane Dixon, EMS Director for Kit Carson County Ambulance Service, opposes the proposed rule because it threatens supple | · | · | |||
La Grange Fire Department GovernmentOppose The La Grange Fire Department, a governmental EMS organization, opposes the proposed rule to limit Ground Emergency Medi | · | · | |||
Laguna Beach Fire Department GovernmentOppose Niko King, Fire Chief of the Laguna Beach Fire Department, opposes the proposed rule capping Medicaid supplemental payme | · | · | |||
Lansing Fire Department GovernmentOppose The Lansing Fire Department, a municipal EMS organization, opposes the proposed rule to limit Ground Emergency Medical T | · | · | · | ||
Lemont Fire Protection District GovernmentOppose The Lemont Fire Protection District, a governmental EMS organization, opposes the proposed rule to limit Ground Emergenc | · | · | · | ||
Lewiston Fire Department GovernmentOppose The Lewiston Fire Department, a municipal fire department providing EMS services in Idaho, opposes the proposed limitati | · | · | |||
Livermore-Pleasanton Fire Department GovernmentOppose Aaron Lacey, Fire Chief of the Livermore-Pleasanton Fire Department, opposes the proposed rule because it would cap Grou | · | · | |||
Lockport Township Fire Protection District GovernmentOppose John O'Connor, Fire Chief of the Lockport Township Fire Protection District, opposes the proposal to limit Ground Emerge | · | · | |||
Manhattan Fire Protection District GovernmentOppose The Manhattan Fire Protection District, a local government EMS organization, opposes the proposed rule to limit Ground E | · | · | · | ||
Marion County Ambulance BusinessOppose Fayette County Ambulance opposes the proposed rule, arguing that it would weaken Alabama's successful ambulance suppleme | · | · | · | ||
Maryland Behavioral Health Coalition AdvocacyOppose The Maryland Behavioral Health Coalition, a group of state and local organizations, opposes the proposed rule because it | · | · | · | · | · |
Massachusetts Call/Volunteer Firefighters Association, Inc. (MCVFA) AdvocacyOppose Joseph V. | · | · | · | · | |
Mehlville Fire Protection District GovernmentOppose The Mehlville Fire Protection District, a local government entity providing fire and EMS services, opposes the proposed | · | · | · | ||
Mendocino County Fire Chiefs Association Trade associationOppose The Mendocino County Fire Chiefs Association opposes the proposed rule because it would cap Ground Emergency Medical Tra | · | · | · | ||
Mid-Columbia Fire & Rescue GovernmentOppose David Jensen, Fire Chief of Mid-Columbia Fire & Rescue, opposes the proposed rule because it would limit supplemental Me | · | · | |||
Mid-County EMS BusinessOppose Kenan M. | · | · | · | ||
Minnesota Hospital Association Trade associationOppose The Minnesota Hospital Association opposes the proposed rule because it expands the scope of Medicare-based payment limi | · | · | · | · | · |
Mississippi Ambulance Alliance Trade associationSupport The Mississippi Ambulance Alliance supports CMS's efforts to strengthen transparency and accountability in Medicaid supp | · | · | · | · | |
Montgomery County Fire and Rescue Service GovernmentOppose The Montgomery County Fire and Rescue Service opposes the proposed targeted payment limits, arguing that fire-based EMS | · | · | · | ||
National City Fire Department GovernmentOppose Sergio Mora, Fire Chief of the National City Fire Department, opposes the proposed rule because it would limit reimburse | · | · | · | · | |
New Jersey Association of Mental Health and Addiction Agencies Trade associationOppose The New Jersey Association of Mental Health and Addiction Agencies, Inc. | · | · | · | · | · |
New Lenox Fire Protection District GovernmentOppose The New Lenox Fire Protection District, a fire-based EMS organization, opposes the proposed rule to limit Ground Emergen | · | · | |||
New York State Council for Community Behavioral Healthcare AdvocacyOppose The NYS Council for Community Behavioral Healthcare opposes the proposed rule because it extends payment caps to mental | · | · | · | · | · |
Newport Beach Fire Department GovernmentOppose Jeff Boyles, Fire Chief of the Newport Beach Fire Department, opposes the proposed rule capping Ground Emergency Medical | · | · | |||
North County Fire Protection District GovernmentOppose The North County Fire Protection District (NCFPD) opposes the proposed rule capping Ground Emergency Medical Transportat | · | · | · | ||
Oceanside Fire Department GovernmentOppose The Oceanside Fire Department opposes the proposed rule capping Ground Emergency Medical Transportation (GEMT) supplemen | · | · | · | ||
Onvida Health Yuma Medical Center BusinessSupport Onvida Health Yuma Medical Center, a large healthcare provider in Arizona, supports the proposed rule but urges CMS to p | · | · | · | · | · |
Orland Fire Protection District GovernmentOppose John Purtill, Fire Chief/Administrator of the Orland Fire Protection District, opposes the proposed rule to limit Ground | · | · | |||
Palatine Fire Department GovernmentOppose The Palatine Fire Department, a municipal EMS organization, opposes the proposed rule that would limit Ground Emergency | · | · | |||
Palos Heights Fire Protection District GovernmentOppose The Palos Heights Fire Protection District, a local fire and EMS department, opposes the proposed rule to limit Ground E | · | · | · | ||
Pasadena Fire Department GovernmentOppose Chad Augustin, Fire Chief of the Pasadena Fire Department, opposes the proposed rule capping Ground Emergency Medical Tr | · | · | · | ||
Paso Robles Professional Firefighters Local 4148 UnionOppose Noah Munds, President of Paso Robles Professional Firefighters Local 4148, opposes the proposed rule because it would ca | · | · | · | ||
Polson Ambulance Inc BusinessSupport Tim Brester, owner of Polson Ambulance Inc, argues that adequate Medicaid reimbursement is essential for the survival of | · | · | · | · | |
Prospect Heights Fire Protection District GovernmentOppose Jason Hardy, Battalion Chief of the Prospect Heights Fire Protection District, opposes the proposed reimbursement cap on | · | · | · | ||
PWW Advisory Group BusinessOppose PWW Advisory Group, a consulting firm for emergency medical services, opposes the proposed Medicare Fee Schedule (AFS) l | · | · | · | ||
Regional One Health BusinessOppose Regional One Health, a safety-net hospital, opposes several aspects of the proposed rule, arguing that it imposes unnece | · | · | · | · | · |
Richmond University Medical Center BusinessSupport Richmond University Medical Center, a nonprofit safety-net hospital, supports the proposed rule but requests a specific | · | · | · | · | · |
Richton Park Fire Department GovernmentOppose Mick Smith, Fire Chief of the Richton Park Fire Department, opposes the proposed rule because it would limit Ground Emer | · | · | · | ||
River Forest Fire Department GovernmentOppose The River Forest Fire Department, a local government fire/EMS organization, opposes the proposed rule to limit Ground Em | · | · | · | · | |
Riverside County Fire Dept. GovernmentOppose Robert Fish, Fire Chief of the Riverside County Fire Department, opposes the proposed rule capping Ground Emergency Medi | · | · | · | ||
San Diego Fire-Rescue Department GovernmentOppose Robert Logan, Fire Chief of the San Diego Fire-Rescue Department, opposes the proposed rule capping Ground Emergency Med | · | · | |||
San Marcos Fire Department GovernmentOppose Dan Barron, Fire Chief of the San Marcos Fire Department, opposes the proposed rule because capping Ground Emergency Med | · | · | · | ||
San Ramon Valley Fire Protection District GovernmentOppose The San Ramon Valley Fire Protection District opposes the proposed cap on supplemental Medicaid payments, arguing that i | · | · | · | ||
Santa Rosa Fire Department GovernmentSupport The Fire Chief of the Santa Rosa Fire Department supports the proposed rule, noting that the department provides critica | · | · | · | ||
Skokie Fire Department GovernmentOppose The Skokie Fire Department opposes the proposed rule to limit Ground Emergency Medical Transportation (GEMT) supplementa | · | · | · | ||
Sonoma Valley Fire District GovernmentOppose The Sonoma Valley Fire District opposes the proposed rule capping Ground Emergency Medical Transportation (GEMT) supplem | · | · | · | ||
South Coast Fire Protection District GovernmentOppose Jason Warner, Fire Chief of the South Coast Fire Protection District, opposes the proposed rule because it would cap Gro | · | · | |||
South Elgin and Countryside Fire Protection District GovernmentOppose William Luchsinger, Fire Chief of the South Elgin and Countryside Fire Protection District, opposes the proposed rule li | · | · | |||
Southern Paramedic Service, Inc. BusinessSupport Gary Padget, CEO of Southern Paramedic Service, Inc, supports the proposed action provided that CMS allows states the fl | · | · | · | · | |
Stryker BusinessOppose Stryker opposes the proposed cap on Medicaid Ground Emergency Medical Transportation (GEMT) supplemental payments, argui | · | · | · | · | |
Sycuan Fire Department GovernmentOppose The Sycuan Fire Department, a fire-based EMS agency, opposes the proposed rule capping Ground Emergency Medical Transpor | · | · | · | ||
Temple University Health System BusinessOppose Abhinav Rastogi, President and CEO of Temple University Health System, opposes the proposed rule because it extends Medi | · | · | · | · | · |
Tennessee Association of Mental Health Organizations Trade associationOppose The Tennessee Association of Mental Health Organizations (TAMHO) opposes the proposed rule because it extends Medicare-b | · | · | · | · | · |
Thompson Valley Emergency Medical Services GovernmentSupport James Robinson, representing Thompson Valley EMS (a Colorado Title 32 Special District), urges CMS to protect the Ground | · | · | · | ||
Truckee Meadows Fire Protection District GovernmentOppose Richard Edwards, Fire Chief of the Truckee Meadows Fire Protection District, opposes the proposed funding caps on Ground | · | · | |||
Ukiah Valley Fire Authority GovernmentOppose Susan Sher, Mayor of Ukiah, is writing on behalf of the Ukiah Valley Fire Authority to oppose the proposal to cap Ground | · | · | · | ||
Ute Pass Regional Health Service District GovernmentOppose The Ute Pass Regional Health Service District, a governmental health service district, opposes the proposed rule because | · | · | |||
Village of Bolingbrook GovernmentOppose The Village of Bolingbrook, representing a municipal fire department, opposes the proposed rule because it replaces cost | · | · | · | ||
Village of Downers Grove GovernmentOppose The Fire Chief of the Village of Downers Grove opposes the proposed rule because it would limit Ground Emergency Medical | · | · | |||
Village of Matteson Fire Department GovernmentOppose The Village of Matteson Fire Department opposes the proposed rule that would limit Ground Emergency Medical Transportati | · | · | · | ||
Village of Oak Park Fire Department GovernmentOppose The Village of Oak Park Fire Department opposes the proposed rule to cap Ground Emergency Medical Transportation (GEMT) | · | · | · | ||
Village of Villa Park Fire Department GovernmentOppose The Village of Villa Park Fire Department opposes the proposed rule to limit Ground Emergency Medical Transportation (GE | · | · | |||
Village of Western Springs GovernmentOppose The Village of Western Springs and its Department of Fire & EMS oppose the proposed rule because it would limit Ground E | · | · | · | ||
Vista Fire Rescue GovernmentOppose Gerard Washington, Fire Chief of Vista Fire Rescue, opposes the proposed rule because capping Ground Emergency Medical T | · | · | · | ||
Washington Council for Behavioral Health Trade associationOppose The Washington Council for Behavioral Health, representing over forty community behavioral health agencies, opposes the | · | · | · | · | · |
Wauconda Fire Protection District GovernmentOppose The Wauconda Fire Protection District, a local government fire/EMS organization, opposes the proposed rule to limit Grou | · | · | · | ||
West Metro Fire Protection District GovernmentSupport The West Metro Fire Protection District, a governmental fire district, urges CMS to protect the Ground Emergency Medical | · | · | · | ||
WestCare AdvocacyOppose WestCare, a national nonprofit behavioral health provider, opposes the proposed rule because it extends restrictive paym | · | · | · | · | · |
Win-Bur-Sew Fire Protection District GovernmentOppose Fire Chief Charles Cunningham of the Win-Bur-Sew Fire Protection District opposes the proposed rule limiting Ground Emer | · | · | |||
Woods System of Care BusinessSupport Woods System of Care, a population health management organization, supports the implementation of the proposed rule but | · | · | · | · | · |
10 organization-typed comments could not be identified.
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
- Jul 21, 2026Pafford Medical Services of ArkansasSupportBusiness📎 Attachment
PaNord Medical Services, an ambulance service provider, supports CMS's efforts to improve transparency in Medicaid supplemental payment programs. They advocate for state flexibility to design payment methodologies that account for the specific operational costs and community needs of EMS providers, such as rural geography and readiness costs.
Read comment → - Jul 21, 2026Fort Sanders Regional Medical CenterOpposeBusiness📎 Attachment
Fort Sanders Regional Medical Center opposes the proposed rule, arguing that it imposes deeper and faster Medicaid payment cuts than required by Congress. The hospital urges CMS to allow aggregate Medicare limit calculations, maintain uniform increase SDPs, and preserve separate payment terms to ensure sufficient funding for patient care.
Read comment → - Jul 21, 2026Pafford Medical Services of MississippiSupportBusiness📎 Attachment
PaNord Medical Services, an ambulance service provider, supports CMS's efforts to improve transparency in Medicaid supplemental payment programs. They advocate for state flexibility to design payment methodologies that account for the high operational costs and specific community needs of EMS providers.
Read comment → - Jul 21, 2026Pafford EMS of OklahomaSupportBusiness📎 Attachment
PaNord Medical Services, an ambulance service provider, supports CMS's efforts to improve transparency in Medicaid supplemental payment programs. They advocate for state flexibility to develop payment methodologies that account for specific operational costs, such as rural service areas, workforce retention, and readiness costs.
Read comment → - Jul 21, 2026Woods System of CareSupportBusiness📎 Attachment
Woods System of Care, a population health management organization, supports the implementation of the proposed rule but requests specific technical adjustments to ensure it remains workable for home and community-based and behavioral health services. They advocate for conforming the rule's scope to the specific categories enacted by Congress, establishing a clear compliance pathway for services without Medicare equivalents, and preserving value-based payment arrangements.
Read comment → - Jul 21, 2026Bath Community HospitalOpposeBusiness📎 Attachment
Bath Community Hospital, a small critical access hospital, opposes the proposed rule because it exceeds the requirements of the law and would significantly reduce federal Medicaid spending. The hospital argues that the proposed changes would increase administrative burdens, reduce funding for essential services in rural areas, and urges CMS to implement the statute as written using provider-class methodologies and a more gradual phase-down.
Read comment → - Jul 21, 2026American Association for HomecareOpposeTrade association📎 Attachment
The American Association for Homecare (AAHomecare) opposes the proposed rule, arguing that it creates significant risks and unintended consequences for durable medical equipment (DMEPOS) suppliers and beneficiaries. They contend that the proposed Medicare-based payment caps and limits will lead to inadequate reimbursement, reduced access to essential home medical equipment, and increased administrative burdens on small businesses.
Read comment → - Jul 21, 2026Balentine Ambulance Service Inc.OpposeBusiness📎 Attachment
Pamela B McBeath of Balentine Ambulance Service, Inc. opposes the proposed rule, arguing that the 100% Medicare payment ceiling for Medicaid state-directed payments fails to cover the actual costs of emergency medical services. She contends that the rule exceeds congressional intent, creates unfair implementation timelines for ambulance providers, and lacks sufficient geographic and operational exceptions for rural and low-utilization services.
Read comment → - Jul 21, 2026Michigan MedicineOpposeAcademic📎 Attachment
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.
Read comment → - Jul 21, 2026Duke-Margolis Institute for Health PolicyOpposeAcademic📎 Attachment
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.
Read comment →
