Comment on CMS-2026-1256-0002

Summary: The Coalition of Long-Term Acute-Care Hospitals opposes the proposed FY 2027 LTCH rate updates and high-cost outlier threshold changes, arguing that the productivity adjustment fails to account for rising labor costs and that the new outlier methodology creates financial instability. They also oppose the expansion of the Post Acute Care Transfer Policy, claiming it creates financial disincentives for hospitals to transfer patients to LTCHs in a timely manner.