Comment on CMS-2026-1256-0002

Summary: The UCSF Team for High-Value Care supports the proposed repeal of alternative pathways for New Technology Add-on Payments (NTAP) and Outpatient Prospective Payment System (OPPS) device pass-through payments. They argue that Breakthrough designations do not guarantee substantial clinical improvement or generalizability to Medicare beneficiaries, and therefore these devices should be subject to standard, more rigorous evidence-based evaluation.