Comment on CMS-2026-1256-0002
Rainfall HealthSupportAdvocacy
Summary: Rainfall Health, an AI-powered clinical operations company, supports the proposed CJR-X model, specifically praising the 90-day episode window and the differentiated stop-loss limits for safety-net hospitals. They argue that the model will improve care coordination and cost-efficiency, provided CMS also strengthens risk adjustment for complex patients, improves data transparency, and aligns the model with geriatric care priorities.
Executive Summary
1.We support CJR-X, including its mandatory, nationwide scope and its alignment with the broader episode-based reform trajectory anchored by the Transforming Episode Accountability Model (TEAM).
2.We strongly support maintaining the 90-day episode window. Evaluation evidence and clinical experience confirm that the majority of avoidable post-acute spending and complications occur after the index discharge, not during the inpatient stay.
3.We recommend strengthening risk adjustment for medically complex, dual-eligible, and frail beneficiaries to prevent selection bias and protect access for the patients most likely to benefit from coordinated care.
4.We support the proposed differentiated stop-loss/stop-gain limits (5% for safety-net, rural, Medicare-Dependent, and Sole Community Hospitals; 20% for all others) and recommend CMS also adopt peer grouping by dual-eligible share for benchmarking, consistent with the Hospital Readmissions Reduction Program.
5.We recommend CMS heavily weigh the THA/TKA PRO-PM in the Composite Quality Score and require transparent, timely PROM data feedback to participants.
6.We recommend CMS shorten the reconciliation and data-feedback cycle and publish target-price methodology with sufficient detail for participants to model performance prospectively.
7.We recommend CMS extend the in-home telehealth G-codes to include geriatric assessment and 4Ms-aligned services, given the median age of the CJR-X population.