Comment on CMS-2026-1916-0001

Summary: Children's Healthcare of Atlanta, a large pediatric health system, opposes the proposed rule because it fears a hospital-specific, cost-based proxy for a Medicare rate will unfairly penalize IPPS-exempt children's hospitals. They argue that because these hospitals serve a high volume of Medicaid patients and have low Medicare volumes, the proposed methodology would undermine the financial sustainability of the pediatric safety net. They recommend using the Medicare Upper Payment Limit (UPL) framework or a national average of actual Medicare payments instead.