Comment on CMS-2026-1256-0002

Summary: Jefferson Health, a large integrated academic delivery and finance system, opposes several aspects of the proposed FY 2027 Medicare IPPS regulations. They argue that the proposed payment updates and DSH reductions are insufficient to cover rising costs, and they specifically advocate against expanding the post-acute transfer policy, making the CJR-X model mandatory, and including ASC-initiated episodes in the TEAM model.