Comment on CMS-2026-1256-0002

Summary: Providence, a nonprofit health system, opposes several aspects of the proposed rule, specifically arguing that the inpatient rate updates are inadequate and that the proposed cuts to DSH payments and outlier thresholds will harm hospital financial stability. They also strongly oppose the mandatory nature of the CJR-X model, advocating instead for voluntary participation and more robust protections for rural and safety-net hospitals.