Comment on CMS-2026-1256-0002

Summary: Penn Medicine, an academic medical center, opposes several components of the proposed FY 2027 IPPS rule, including the proposed payment update, DSH payment reductions, and the expansion of the post-acute care transfer policy. They specifically argue against the mandatory expansion of the CJR-X model and the inclusion of ambulatory surgical centers in the TEAM model, advocating instead for voluntary participation and protections for safety-net and rural providers.