NAMD Comments on CMS’ State Directed Payments Proposed Rule

On July 21, 2026, NAMD submitted comments on CMS’ proposed rule, Medicaid Program; Medicaid Managed Care State Directed Payments and Medicaid Fee-for-Service Targeted Medicaid Practitioner Payments.

Medicaid agencies share CMS’ commitment to effectively steward taxpayer resources and safeguard program integrity while ensuring access and robust quality of care for Medicaid members. State directed payments (SDPs) serve as an important tool for states and territories to strengthen provider networks, advance quality initiatives, support delivery system transformation, and improve access to care. While Medicaid agencies support CMS’ goal of establishing clear and sustainable parameters for SDP financing, agencies encourage CMS to preserve state and territory flexibility in key areas, minimize unnecessary administrative burden, and provide sufficient transition time and clear pathways for existing arrangements. NAMD’s recommendations include limiting the Medicare-based payment caps to the services identified in law, providing flexibility for services without a meaningful Medicare equivalent, and partnering with Medicaid agencies to develop feasible provider- and service-level reporting methodologies.

Read NAMD’s full comments here.