Comment on CMS-2026-1256-0002
Allina HealthOpposeAdvocacy
Summary: Allina Health, a nonprofit health system, opposes the proposed FY 2027 IPPS rule, arguing that the 2.4 percent payment rate increase is inadequate to cover rising costs and that the DSH uncompensated care calculations lack sufficient explanation and data. They specifically criticize the restrictive new low-volume hospital criteria and the lack of transparency regarding the assumptions used for Factor 1 and Factor 2 calculations.
Dear Administrator Oz:
On behalf of Allina Health, this letter is in response to the request for comments on the Fiscal Year (FY) 2027 Hospital Inpatient Prospective Payment System (IPPS) proposed rule. We appreciate the opportunity to provide comments, which focus on payment updates, quality program modifications, changes to the Transforming Episode Accountability Model (TEAM), the newly proposed Comprehensive Joint Replacement Expansion (CJR-X) model, provider-based location criteria, reasonable cost payment policies, and more.
Please see the attached document for the entirety of our comments.