Comment on CMS-2026-1256-0002

Summary: The Virginia Hospital & Healthcare Association (VHHA) opposes several aspects of the proposed rule, arguing that the 2.4 percent net IPPS payment update is insufficient to cover rising operational costs and that proposed DSH and UCC payment reductions will harm safety-net hospitals. They also express significant concern regarding the mandatory expansion of the CJR-X model, the removal of homelessness codes from the CC list, and the addition of new quality measures without adequate transition periods or risk adjustment.