Comment on CMS-2026-1256-0002

Summary: The Healthcare Association of New York State (HANYS) opposes several aspects of the proposed rule, specifically arguing that the payment update is inadequate to cover hospital costs and that the proposed outlier threshold increase is too high. They also express significant opposition to the mandatory participation in the CJR-X model, the proposed restrictions on nursing and allied health education cost allocations, and the narrowing of provider-based location criteria for off-campus facilities.