Comment on CMS-2026-1256-0002
Essentia HealthOpposeAdvocacy
Summary: Essentia Health, a healthcare system serving rural regions, opposes the proposed FY 2027 Medicare IPPS payment update as insufficient to cover inflation and labor costs. They also argue against the expansion of mandatory episode-based payment models and request more favorable criteria for the Low-Volume Hospital adjustment program.
On behalf of Essentia Health, we write to provide comments on the Fiscal Year (FY) 2027 Medicare hospital inpatient prospective payment system (IPPS) proposed rule. Overall, we are concerned that the proposed payment update is not adequate to cover rising costs due to inflation and labor shortages. We are concerned that the proposed payment update is insufficient to reflect inflation, workforce shortages, and the financial realities facing hospitals, particularly rural providers. Next, our comments urge CMS to adopt a more measured, operationally feasible approach to quality reporting and interoperability changes. Interoperability and burden-reduction proposals are steps in advancing data exchange, but payer accountability must accompany electronic prior authorization requirements. Finally, our comments oppose the continued expansion of mandatory episode-based payment models such as TEAM and CJR-X and instead support voluntary participation and more statistically sound thresholds. Please see attached letter for our full public comment.