Comment on CMS-2026-1256-0002

Summary: King & Spalding LLP, representing over 700 hospitals, opposes the proposed rule because it continues to arbitrarily exclude certain "wage and wage-related costs" from the Medicare payment formula. They argue that CMS is violating the Medicare statute and previous court rulings by excluding costs that are clearly labor-related, such as professional fees and financial services, which CMS itself acknowledges as labor-related by using the Employment Cost Index to calculate their inflation.