Comment on CMS-2026-1256-0002

Summary: HonorBridge, a non-profit organ procurement organization, opposes several proposed changes to the Medicare IPPS and LTCH PPS payment methodologies, particularly the extension of year-end reconciliation to non-renal organs and the shift of Standard Acquisition Charge (SAC) setting to Medicare Administrative Contractors. They argue these changes threaten OPO solvency, hinder technological innovation, and fail to account for the unique operational realities and mission-driven costs of organ recovery.