Comment on CMS-2026-1256-0002

Summary: Northwell Health Systems, a large private health system, provides a mixed response to the proposed rule, agreeing with several MS-DRG reassignments and creations while opposing specific changes to surgical hierarchies and severity levels for social determinants of health (SDOH). They specifically argue against downgrading the severity level of homelessness-related codes and request that CMS maintain current CC designations to reflect the complexity of caring for these populations.