
In January 2026, ANCOR submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) under a Paperwork Reduction Act (PRA) notice. The organization focused its comments on Medicaid fee for service payment rates and how states report proposed changes to those rates. ANCOR urged CMS to require stronger, more detailed information from states when they plan to restructure or reduce Medicaid fee for service payment rates. The group framed the issue as one of transparency and oversight, arguing that current reporting practices can leave critical gaps when significant payment updates move forward.
Push for stronger state reporting
ANCOR’s comments emphasized that insufficient reporting can allow payment changes to proceed without adequate transparency or oversight. The organization highlighted the practical stakes for the IDD care field. It warned that payment changes can significantly affect provider stability and access to services for individuals with intellectual and developmental disabilities.
The comments specifically pointed to the moment when states plan to restructure or reduce Medicaid fee for service rates as a key point where stronger reporting expectations could improve accountability. ANCOR’s position is that CMS should require more complete information at that stage so the impacts of proposed payment changes are not obscured by limited documentation.
Focus on access, workforce, and sustainability
By participating in the PRA process, ANCOR said it aims to ensure CMS has the data needed to fully assess the impact of proposed rate changes. The organization identified several areas it believes CMS should be able to evaluate more clearly based on state reporting. Those areas include service access, workforce stability, and the long term sustainability of community based providers. In ANCOR’s view, stronger reporting would better equip CMS to understand how rate restructuring or reductions could affect whether services remain available, whether the workforce supporting those services remains stable, and whether providers can sustain operations over time.
Part of broader scrutiny on payment transparency
ANCOR’s effort also aligns with broader federal scrutiny of Medicaid payment transparency. The organization’s comments reflect growing concerns about how states manage cost pressures without undermining essential supports. Taken together, the submission positions improved rate reporting as a key lever for oversight when Medicaid fee for service payment rates are proposed for restructuring or reduction, particularly in ways that may affect the IDD services system.

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