Comment on CMS-2026-1256-0002
UPMCSupportAdvocacy
Summary: The University of Pittsburgh Medical Center (UPMC) supports the transition toward value-based care models like TEAM and CJR-X but requests several modifications to ensure operational feasibility. They argue for extended lookback periods for risk adjustment, phased implementation timelines for new hospitals, and the alignment of reporting requirements across multiple concurrent models to reduce administrative burden.
UPMC respectfully submits this comment for CMS rule.