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Health Equity and Access

Proposed federal regulations would limit state authority to expand the behavioral health workforce in Medicaid programs

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American Psychological Association. (2026, October 19). Proposed federal regulations would limit state authority to expand the behavioral health workforce in Medicaid programs. https://www.apaservices.org/advocacy/news/limit-authority-behavioral-health-medicaid

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On May 22, 2026, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule concerning state-directed payment (SDP) arrangements in Medicaid programsopens in new window that utilize a managed care system. While hospitals typically receive the bulk of this funding, states also often rely on these arrangements to bring in more behavioral health providers willing to participate in their Medicaid program.

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While Congress made some targeted adjustments to the program in last summer’s One Big Beautiful Bill Act (H.R. 1)opens in new window, the proposed rule makes broad changes to SDP arrangements. For example, while H.R. 1 imposed SDP payment limitations on specific kinds of entities, the proposed rule extends these constraints to all providers and entities receiving SDPs. On July 17, 2026, APA Services filed a response to the proposed rule (PDF, 197KB)opens in new window highlighting the ways in which CMS exceeded its authority, their impact on access to behavioral health care, and the effect the new guidelines will have on existing and future SDP arrangements.

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