Comment on CMS-2026-1256-0002

Summary: The Massachusetts Health & Hospital Association (MHA) opposes several aspects of the proposed FY 2027 IPPS rule, arguing that the market basket update is insufficient to cover rising labor and supply costs and that the productivity adjustment is too high for the clinical setting. They also request the withdrawal of proposals regarding organ acquisition cost allocations, Z-code severity level reversals, and the removal of alternative pathways for new technology add-on payments.