Comment on CMS-2026-1256-0002

Summary: The Duke-Margolis Institute for Health Policy supports the proposed rule's expansion of the CJR-X model and the repeal of certain NTAP pathways for breakthrough devices to better align Medicare spending with value. However, the Institute opposes the repeal of the alternative NTAP pathway for antimicrobials, arguing that it is necessary to combat antimicrobial resistance and reduce hospital costs.