Comment on CMS-2026-1916-0001

Summary: The Greater New York Hospital Association (GNYHA) opposes the proposed rule, arguing that CMS's implementation of Medicare-based payment limits exceeds statutory authority and imposes significant administrative burdens on states and providers. They specifically advocate for aggregate rather than per-service compliance monitoring, a smoother phase-down methodology for grandfathered payments, and the preservation of separate payment terms and provider class flexibility.