Comment on CMS-2026-1256-0002

Summary: The Children’s Hospital Association (CHA) opposes several proposed changes, specifically those regarding provider-based requirements for off-campus facilities, restrictions on resident training experience, and the transition to a reasonable cost reconciliation process for non-renal organ acquisition. They argue that these policies fail to account for the unique regional referral networks and specialized clinical infrastructure required for pediatric care, potentially creating administrative burdens and barriers to access for children with complex needs.