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CMS Seeking Comments on Medicaid State Directed Payments Including Provider Assessment, IGT, and GEMT, Proposed Rules

July 15, 2026, by Shawn Baird

The AAA will be submitting comment about the underfunding of ambulance service to CMS in it’s rulemaking on Medicaid State Directed Payments. Many states have implemented Medicaid supplemental payment programs. Under HR.1, passed last July, no additional states may implement these programs. Additionally states that have them must not exceed Medicare payment for the same services. Because of the state by state variablility of these programs, the AAA is focusing it’s comment on the fact that basing payment on Medicare is insufficient to assure patient access to vital ambulance services. Medicare has been demonstrated through multiple studies to pay well below cost for ambulance services.

Attached are the AAA comments, as well as a guide that individual companies and state associations may wish to use in formulating their own comment letter, specific to their state situation.

State and Agency Comment to CMS on SDP Rule

Final-SDP-CMS-Rule-Comment-Letter-7.10.2026

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