Comment on CMS-2026-1256-0002
University of Colorado Health (UCHealth)SupportBusiness
Summary: UCHealth, a healthcare organization, supports the proposed changes to the Promoting Interoperability Program but requests more realistic implementation timelines and flexibility. They argue that the technical complexity of new requirements—such as Electronic Prior Authorization and Unique Device Identifiers—requires significant IT investment, vendor coordination, and phased rollouts to be operationally feasible.
On behalf of UCHealth, we appreciate the opportunity to comment on the CY 2027 IPPS Proposed Rule, with particular focus on the IPPS Promoting Interoperability Program. We commend CMS for its continued emphasis on advancing access, quality, health equity, and value based care through this program and more broadly across the inpatient prospective payment system.
Drawing on our experience with Medicare inpatient operations and implementation of Promoting Interoperability requirements, we offer the following comments and recommendations. From UCHealth’s perspective, the evolution of the Promoting Interoperability Program is fundamentally dependent on significant and growing IT investments, including electronic health record (EHR) optimization, interoperability infrastructure, data standardization, and system integration across clinical, operational, and administrative platforms.
Please see the attached document for the full public comments from University of Colorado Health (UCHealth) IT teams.