Comment on CMS-2026-1256-0002

Summary: The Greater New York Hospital Association (GNYHA), representing over 200 hospitals, opposes several aspects of the proposed CJR-X model, specifically the lack of a "glide path" to risk and the inclusion of upfront discount factors. They argue that the current proposal prioritizes quick savings over sustainable reform and advocate for a phased risk approach, more granular regional pricing, and the removal of discount factors to protect hospital financial stability.