Comment on CMS-2026-1256-0002
Rainfall HealthSupportBusiness
Summary: Rainfall Health, an AI-powered clinical operations company, supports the proposed rolling baseline for the Composite Quality Score (CQS) and the expansion of the TEAM model to ambulatory surgery centers (ASCs). However, they request specific modifications to ensure the CQS rewards year-over-year improvements for high-acuity hospitals and that ASC inclusion includes robust risk adjustment, clear attribution rules, and pre-defined quality measures.
Our comments address two sections of the Proposed Rule. The first concerns the construction of the Composite Quality Score (CQS) using data from the Hospital Inpatient Quality Reporting (IQR), Hospital Outpatient Quality Reporting (OQR), and Hospital Acquired Condition (HAC) Reduction programs, and the proposed shift from a fixed historical baseline to a rolling window of performance data that updates annually. The second responds to CMS's Request for Information regarding the potential extension of TEAM to ambulatory surgery centers (ASCs).