Comment on CMS-2026-1256-0002

Summary: Capital District Physicians’ Health Plan, Inc. (CDPHP) supports the proposed rule's integrated approach to quality and sustainability but urges CMS to adopt stricter safeguards against hospital reclassification abuses. The organization argues that current loopholes allow large urban hospitals to "gamify" rural status to artificially inflate rates, creating financial instability for Medicare Advantage plans and undermining the predictability of industry benchmarks.