Comment on CMS-2026-1256-0002

Summary: CommonSpirit Health, a nationwide faith-based safety-net provider, opposes several key components of the proposed rule, specifically the mandatory nature of the CJR-X bundled payment model and the inclusion of ambulatory surgical centers or physician-owned hospitals in the TEAM model. They argue that mandatory participation creates undue financial risk for safety-net and low-volume hospitals and request that CMS instead make these programs voluntary.