Comment on CMS-2026-1256-0002

Summary: ScionHealth, a provider of long-term acute care hospitals (LTCHs), opposes the proposed FY 2027 ratesetting methodology because it relies on unmodified cost report data from the COVID-19 pandemic period. The organization argues that using this "aberrant" data will lead to permanent underpayment and distorted wage indices, and they instead advocate for modified methodologies that account for post-pandemic trends and high labor costs.