Premier Weighs in on Medicaid Managed Care State Directed Payments Proposed Rule

Premier submitted comments in response to the Medicaid Managed Care State Directed Payments and Medicaid Fee-for-Service (FFS) Targeted Medicaid Practitioner Payments proposed rule. The policies proposed by CMS result from implementation of Public Law 119-21, “The Working Families Tax Cuts Act” (WFTC)—otherwise known as the One Big Beautiful Bill Act. Based on Congressional Budget Office projections, implementation of the law is expected to decrease federal spending on Medicaid by hundreds of billions over the next 10 years, which could have far-ranging impacts on healthcare delivery and access to care, especially in rural areas. As such, Premier urged CMS to be thoughtful in implementing the law.

In our detailed letter, Premier urged CMS to:

• Not implement policies that go beyond the specifically delineated scope and parameters specified by Congress in section 71116 of Public Law 119-21;
• Consider using the same methodologies that have long been used to establish the Medicare-based upper payment limit (UPL) in FFS Medicaid;
• Specify carveouts to allow for (i) value-based care and other innovative payment models; (ii) directing additional resources to underserved areas; and (iii) the availability of disaster relief;
• Reduce the operational burden of the final rule by simplifying the compliance framework wherever possible, including streamlining documentation, approval, and reporting expectations; and
• Ease the transition of grandfathered SDPs to the statutorily required funding limits by rebasing the amount that is reduced by 10 percent every year, until the desired payment limit is reached.