ACHP Comments on CMS Medicaid State Directed Payments Rule

The Alliance of Community Health Plans submitted comments to CMS on the proposed rule governing Medicaid managed care state-directed payments (CMS-2449-P). While ACHP supports strengthening program integrity and implementing OBBBA, the organization cautions that several provisions extend beyond the statute—restricting state flexibility and imposing service-level compliance requirements that don’t align with how managed care is financed. ACHP’s recommendations focus on preserving Congress’s statutory framework, aligning compliance with managed care operations, protecting value-based care and delivery system innovation and ensuring clear, workable implementation. ACHP also signed on to America’s Essential Hospitals letter to CMS.