The AHA provided comments July 21 to the Centers for Medicare & Medicaid Services on its proposed rule to modify policies governing Medicaid state-directed payments as authorized under the July 2025 reconciliation bill. The rule also includes proposals that are beyond what the statute requires, such as new limits on certain targeted fee-for-service payments and other SDP service types, as well as new limitations on SDP design. The AHA said that CMS’ projection of a $510.1 billion reduction in payments over 10 years well exceeds the Congressional Budget Office’s estimate of $149.4 billion over 10 years, and would greatly reduce access to care, exacerbate workforce challenges, and impact hospital and health system financial viability if proposed changes in the rule are enacted. The AHA urged CMS to rescind proposals that exceed statutory requirements and to lessen the financial impact of the reduction of SDPs to Medicare levels. 

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