Comment on CMS-2026-1256-0002

Summary: The Alliance of Safety-Net Hospitals (ASH) opposes several components of the proposed FY 2027 Medicare IPPS regulations, arguing that the proposed payment updates and DSH reductions are insufficient to cover rising costs. They specifically advocate for a voluntary rather than mandatory participation framework for the CJR-X model, oppose the expansion of the post-acute care transfer policy, and request the withdrawal of new cost-reporting requirements that they believe impose undue administrative burdens.