Utah Providers Applaud Finalized UPL Program

CMS has approved SPA 24-0003 for the state of Utah, effective July 1, 2026. The amendment formally adds supplemental UPL payments for participating non-state government-owned, or NSGO, nursing facilities, and updates Utah’s nursing facility benefit to more closely align with the services included under Medicare’s PDPM methodology.

The Upper Payment Limit (UPL) is a federal regulatory ceiling set by CMS that caps the total amount a state may pay to a specific class of providers under Medicaid. It ensures that total Medicaid payments for a given provider type do not exceed what Medicare would have paid for the same services.

So, the basics are for a nursing facility that is owned by a qualifying non-state governmental entity and has an agreement with Utah Medicaid it can receive a supplemental payment above the normal Medicaid rate, subject to the federal UPL. The non-federal share of those payments is funded through Intergovernmental Transfers, or IGTs, from local governmental entities. Utah already maintains a specific NSGO nursing facility UPL program, participation process and IGT certification process for those entities.

Milestone for Utah

Allie Spangler, the president and CEO of the Utah Health Care Association, said “this approval is incredibly significant for Utah’s nursing facilities. The UPL program isn’t simply supplemental revenue—it is a critical part of keeping our Medicaid nursing facility system financially viable.”

Without it, she said, many facilities would struggle to sustain operations, and some would ultimately be forced to close.

“Just as importantly, CMS’s approval sends a clear message that the fundamental structure of Utah’s UPL program is sound. There has been a tremendous amount of scrutiny and uncertainty surrounding these programs nationally, so having CMS approve Utah’s methodology gives our providers important confidence that a properly structured UPL program continues to have a place in Medicaid financing,” Spangler said.

“We’ve spent years working with our state partners and providers to get this program right, because we know how critical this funding is to the stability of Utah’s nursing facilities. This approval is a major milestone, but more importantly, it helps ensure that Utah’s nursing facilities can continue caring for some of our state’s most vulnerable residents”

Comments or questions? Contact Patrick Connole at pconnole@parkplacelive.com.