Comment on CMS-2026-1256-0002

Summary: The Institute for Gene Therapies (IGT), a multi-stakeholder coalition, opposes the proposed repeal of the NTAP Alternative Pathway. They argue that the current IPPS system is inadequate for high-cost gene therapies and instead recommend creating an enhanced NTAP pathway with 100% cost reimbursement and establishing individual MS-DRGs for each FDA-approved gene therapy.