AAMC
AdvocacyOppose
Medicare Program: Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2027 Rates; Requirements for Quality Programs; and Other Policy Changes
CMS-2026-1256-0002Proposed Rule
Comments
926
Awaiting comments
Deadline
Closed on Jun 10, 2026
Closed Jun 10, 2026
Net supportiSupport minus oppose · campaigns included
+12%
+12% excluding campaigns
Document
Details
The document's own metadata, straight from the source system.
- Title
- Medicare Program: Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2027 Rates; Requirements for Quality Programs; and Other Policy Changes
- Posted
- Apr 14, 2026
- Comment period
- Apr 14, 2026 – Jun 10, 2026
- FR Doc
- 2026-07203
- CFR
- 42 CFR Parts 405 412 413 415 419 495 512
Analysis
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Include campaigns
Stance breakdown
+12%
Net support
Support406Oppose294Other226
Aggregates include form-letter campaigns. Excluding them, net support is +12% across organic comments.
Who commented
Breakdown by commenter type.
Individual
420
Government
1
Trade association
2
Advocacy
269
Academic
18
Business
212
Other
4
Comments over time
Weekly arrivals, stacked by stance.
Posted Apr 14, 2026Deadline Jun 10, 2026
May 11May 18May 25Jun 1Jun 8
Support406Oppose294Other226
Support × commenter type
How each type splits across stance.
Support
Oppose
Other
Individual
50%
17%
33%
Advocacy
38%
43%
19%
Business
40%
47%
13%
Academic
22%
33%
44%
Other
75%
0%
25%
Trade association
0%
100%
0%
Government
100%
0%
0%
Issues raised
The docket's canonical issues. Select one to browse its comments.
Breakthrough device alternative pathways158
Repeal of ntap alternative pathway126
Methodology and risk adjustment102
Physician ownership of hospitals83
Substantial clinical improvement criteria82
Impact on rural healthcare access72
Opo reimbursement and operational impact57
Advance care planning ecqm53
New ms-drgs for spinal fusions42
Electronic prior authorization burden40
Position map
Who stands where on each issue?
Every non-silent position is backed by an excerpt from the comment.
Issues shown
Uncheck an issue to choose another.
| Organization | Breakthrough device alternative pathways | Repeal of ntap alternative pathway | Methodology and risk adjustment | Impact on rural healthcare access | Inadequate ipps payment rate increase |
|---|---|---|---|---|---|
AAMC AdvocacyOppose The Association of American Medical Colleges (AAMC) opposes several components of the proposed FY 2027 IPPS rule, specif | · | · | · | · | · |
Abbott BusinessOppose Abbott, a medical technology and nutrition manufacturer, opposes the proposed repeal of the alternative NTAP and OPPS de | · | · | · | ||
Abridge AdvocacySupport Abridge, an AI platform for clinical documentation, supports CMS's efforts to improve quality measurement and reduce adm | · | · | · | · | · |
Adagio Medical, Inc. BusinessOppose Adagio Medical, Inc., a medical device company, opposes the proposal to eliminate the Alternative Pathway for the New Te | · | · | · | ||
AdvaMed AdvocacyOppose The Advanced Medical Technology Association (AdvaMed) opposes CMS's proposal to repeal the alternative New Technology Ad | · | · | · | ||
AdventHealth AdvocacySupport AdventHealth, a national non-profit healthcare system, generally supports the proposed FY 2027 IPPS updates, including t | · | · | · | · | · |
Adventist Health AdvocacyOppose Adventist Health, a nonprofit health system, opposes several provisions of the proposed FY 2027 IPPS rule, arguing that | · | · | · | · | · |
Adventist Health Policy Association AdvocacySupport The Adventist Health Policy Association (AHPA), representing a large network of health systems, generally supports the p | · | · | · | · | · |
Advocate Health AdvocacyOther Advocate Health, a nonprofit integrated health system, submitted a comprehensive set of comments regarding the FY 2027 I | · | · | · | ||
AgNovos Bioscience, Inc. BusinessSupport AgNovos Bioscience, Inc., a medical device company, argues that the AGN1 Local Osteo-Enhancement Procedure (LOEP) should | · | · | · | · | · |
AHIP AdvocacySupport AHIP, a national association representing health insurance plans, supports the proposed FY 2027 IPPS and LTCH PPS rules, | · | · | · | · | · |
Alabama Hospital Association AdvocacyOther The Alabama Hospital Association is submitting a comment on behalf of its member hospitals, expressing mixed views on th | · | · | · | · | |
Alliance for Patient Access AdvocacySupport The Alliance for Patient Access, a national network of healthcare providers, supports the approval of the New Technology | · | · | · | · | |
Alliance of Safety-Net Hospitals AdvocacyOppose The Alliance of Safety-Net Hospitals (ASH) opposes several components of the proposed FY 2027 Medicare IPPS regulations, | · | · | · | · | · |
Alliance on Hospital Reimbursement AdvocacyOppose The Alliance on Hospital Reimbursement, representing 137 hospitals, opposes the proposed FY 2027 IPPS rates and policies | · | · | · | ||
Allina Health AdvocacyOppose Allina Health, a nonprofit health system, opposes the proposed FY 2027 IPPS rule, arguing that the 2.4 percent payment r | · | · | · | · | |
Altera Digital Health AdvocacyOther Altera Digital Health provides mixed feedback on the proposed rule, supporting the removal of certain eCQMs and the incl | · | · | · | · | · |
America's Essential Hospitals AdvocacyOppose America's Essential Hospitals, an association representing hospitals serving low-income and rural populations, opposes s | · | · | · | · | · |
American Academy of Hospice and Palliative Medicine AdvocacySupport The American Academy of Hospice and Palliative Medicine (AAHPM) supports the adoption of advance care planning (ACP) qua | · | · | · | · | · |
American Association of Hip and Knee Surgeons AdvocacyOppose The American Association of Hip and Knee Surgeons (AAHKS) opposes the proposed CJR-X model, arguing that it is too aggre | · | · | · | · | |
American Association of Neurological Surgeons / Congress of Neurological Surgeons AdvocacySupport The American Association of Neurological Surgeons (AANS) and the Congress of Neurological Surgeons (CNS) support the cre | · | · | · | · | · |
American Association of Orthopaedic Surgeons AdvocacyOppose The American Association of Orthopaedic Surgeons (AAOS) opposes the mandatory nature of the proposed TEAM and CJR-X alte | · | · | · | · | · |
American College of Cardiology AdvocacyOther The American College of Cardiology (ACC) provides a mixed response to the proposed rule, expressing support for several | · | · | · | ||
American College of Obstetricians & Gynecologists AdvocacyOther The American College of Obstetricians and Gynecologists (ACOG) submitted a detailed comment providing various recommenda | · | · | · | · | |
American College of Surgeons AdvocacyOther The American College of Surgeons (ACS) provides a comprehensive set of recommendations regarding the proposed Medicare I | · | · | · | · | |
American Diabetes Association AdvocacyOther The American Diabetes Association (ADA) provides mixed feedback on the proposed rule, strongly supporting the inclusion | · | · | · | ||
American Hospital Association AdvocacyOppose The American Hospital Association (AHA) opposes the mandatory nature of the proposed CJR-X Model, arguing that it places | · | · | · | · | |
American Medical Association AdvocacyOther The American Medical Association (AMA) submitted a detailed comment providing mixed feedback on the proposed FY 2027 Med | · | · | · | · | · |
American Pharmacists Association AdvocacyOppose The American Pharmacists Association (APhA) opposes the proposed removal of COVID-19 vaccination reporting measures for | · | · | · | · | · |
American Society for Transplantation and Cellular Therapy AdvocacyOther The American Society for Transplantation and Cellular Therapy (ASTCT) provides feedback on the FY 2027 IPPS proposed rul | · | · | · | · | · |
AMGA AdvocacyOther The American Medical Group Association (AMGA) submitted a mixed-stance comment regarding the FY 2027 IPPS and LTCH propo | · | · | · | · | · |
Amgen, Inc. BusinessSupport Amgen, a pharmaceutical company, supports the CMS proposal to continue New Technology Add-on Payment (NTAP) status for i | · | · | · | · | |
AQUAPASS, Inc BusinessOppose AQUAPASS, Inc., a medical device company, opposes the proposed repeal of the alternative New Technology Add-On Payment ( | · | · | · | · | |
Arboretum Ventures AdvocacyOppose Arboretum Ventures, a healthcare venture capital firm, opposes CMS's proposal to eliminate the alternative NTAP and TPT | · | · | · | ||
Arthrex, Inc. BusinessOppose Arthrex, Inc., a medical device company, opposes CMS's proposal to repeal alternative pathways that allow Breakthrough D | · | · | · | ||
Ascension AdvocacyOther Ascension, a non-profit Catholic health system, submitted a detailed comment expressing mixed positions on the proposed | · | · | · | ||
Association for Health Care Resource & Materials Management of the American Hospital Association AdvocacySupport The AHRMM Learning UDI Communities (LUC), a collaborative forum of healthcare stakeholders, supports the adoption of Uni | · | · | · | · | · |
Association of Organ Procurement Organizations AdvocacyOppose The Association of Organ Procurement Organizations (AOPO) opposes the proposed expansion of kidney acquisition cost reco | · | · | · | · | |
Association of periOperative Registered Nurses AdvocacySupport The Association of periOperative Registered Nurses (AORN) supports the proposed rule but advocates for the mandatory inc | · | · | · | · | · |
Aveera Medical, Inc. BusinessOppose Aveera Medical, a medical device company, opposes the proposed elimination of the Alternative Pathway for Breakthrough D | · | · | · | · | |
Basilea Pharmaceitica International Ltd. BusinessOppose Basilea Pharmaceutica International Ltd. | · | · | · | · | |
BayCare Health System BusinessOther BayCare Health System, a non-profit healthcare provider, argues that the proposed 2.4% payment update fails to keep pace | · | · | · | · | |
BEAM Alliance AdvocacyOppose The BEAM Alliance, representing a group of pharmaceutical companies, opposes the proposal to repeal the alternative path | · | · | · | · | |
Becton, Dickinson and Company (BD) AdvocacyOppose BD (Becton, Dickinson and Company) opposes the proposed repeal of the alternative NTAP and OPPS device pass-through path | · | · | · | ||
Billings Clinic Logan Health BusinessOppose Billings Clinic Logan Health opposes the proposed FY 2027 market basket update, arguing that the 2.4% increase is insuff | · | · | · | · | |
BJC Health BusinessSupport BJC Health System, representing over twenty hospitals, supports the proposed Expanded Comprehensive Care for Joint Repla | · | · | · | · | |
Blue Cross Blue Shield Association (BCBSA) AdvocacySupport The Blue Cross Blue Shield Association (BCBSA) supports the majority of the proposed changes to the Medicare Hospital In | · | · | · | · | · |
BONESUPPORT, Inc. BusinessSupport BONESUPPORT, Inc. | · | · | · | · | |
Boston Scientific Corporation BusinessOppose Boston Scientific Corporation opposes the proposed repeal of the Alternative Pathways for New Technology Add-on Payment | · | · | · | · | |
Bristol Myers Squibb AdvocacySupport Bristol Myers Squibb supports the proposed methodology for MS-DRG 018 relative weight calculations, arguing it accuratel | · | · | · | · | · |
Bruin Biometrics, LLC BusinessSupport Bruin Biometrics, LLC, a manufacturer of a pressure injury management device, supports the proposed rule's efforts to in | · | · | · | · | |
Cascade Life Alliance AdvocacyOppose Cascade Life Alliance (CLA), a federally designated Organ Procurement Organization (OPO), opposes the proposed expansion | · | · | · | · | |
Catholic Health Association of the United States AdvocacyOther The Catholic Health Association of the United States (CHA) submitted a detailed comment expressing mixed positions on va | · | · | · | · | |
CellTrans Inc BusinessOther CellTrans Inc., the manufacturer of Lantidra, supports the proposal to move islet cell procedures out of kidney-related | · | · | · | · | · |
CentraCare Health BusinessSupport CentraCare Health, a healthcare organization, supports the proposed transition to value-based care and efforts to improv | · | · | · | · | |
Ceribell AdvocacyOppose Ceribell, a medical technology company, opposes the proposal to repeal the Alternative Pathway for Breakthrough Devices | · | · | · | ||
Cleveland Clinic BusinessOppose Cleveland Clinic, a large non-profit healthcare system, opposes several components of the proposed rule, specifically th | · | · | · | · | · |
Coalition of Long-Term Acute-Care Hospitals AdvocacyOppose The Coalition of Long-Term Acute-Care Hospitals opposes the proposed FY 2027 LTCH rate updates and high-cost outlier thr | · | · | · | · | |
Coalition to Transform Advanced Care AdvocacySupport The Coalition to Transform Advanced Care (C-TAC) supports the proposed rule, specifically praising the new advance care | · | · | · | · | · |
Confluence Health BusinessOppose Confluence Health, a healthcare provider, opposes the proposed FY 2027 Medicare payment updates, arguing that the market | · | · | · | · | · |
Connected Health Initiative AdvocacySupport The Connected Health Initiative (CHI), a multistakeholder organization, supports the proposed changes to the Medicare Pr | · | · | · | · | · |
Connecticut Hospital Association AdvocacyOther The Connecticut Hospital Association (CHA) submitted a mixed response to the proposed rule, expressing support for some | · | · | |||
ConnectLife AdvocacyOppose ConnectLife, an Organ Procurement Organization (OPO), opposes the proposed changes to reimbursement for non-renal organ | · | · | · | · | · |
Cook Group, Inc. AdvocacyOther Cook Group, a medical technology manufacturer, expresses a mixed position on the proposed rule. | · | · | · | ||
Cordis BusinessOppose Cordis, a medical technology manufacturer, opposes the proposed elimination of the Alternative Pathway for the New Techn | · | · | · | ||
Covisus Inc. AdvocacyOther Covisus, a supply chain traceability solution provider, argues that the proposed rule creates a compliance burden for ho | · | · | · | · | · |
Danaher AdvocacySupport Danaher Diagnostics, an advocacy organization representing the diagnostics industry, supports the proposed MS-DRG refine | · | · | · | ||
Denver Health and Hospital Authority AdvocacyOppose Denver Health, a public safety-net health system, opposes several components of the FY 2027 IPPS Proposed Rule that they | · | · | · | · | |
Dialysis Vascular Access Coalition AdvocacyOther The Dialysis Vascular Access Coalition (DVAC) expresses a mixed position, supporting the new RAPID coverage pathway whil | · | · | · | · | · |
Digital Quality Implementers Community (facilitated by Leavitt Partners AdvocacySupport The Digital Quality Implementers Community (DQIC) supports CMS's goals of improving quality measurement and reducing adm | · | · | · | · | · |
Donor Network of Arizona AdvocacyOppose The Donor Network of Arizona, a federally designated Organ Procurement Organization, opposes the proposed IPPS Rule beca | · | · | · | · | · |
Donor Network West AdvocacyOppose Donor Network West, an organ procurement organization, opposes the proposed rule's organ acquisition cost provisions, ar | · | · | · | · | · |
Duke-Margolis Institute for Health Policy AdvocacySupport The Duke-Margolis Institute for Health Policy supports the proposed rule's expansion of the CJR-X model and the repeal o | · | · | · | ||
EBR BusinessSupport EBR Systems, Inc., a medical technology company, supports the proposed reassignment of WiSE cases to specific MS-DRGs an | · | · | · | · | · |
Edgewood Surgical Hospital BusinessSupport Edgewood Surgical Hospital, a physician-led specialty hospital, supports CMS policies that allow physician-owned hospita | · | · | · | · | · |
Emplify Health AdvocacyOther Emplify Health, a physician-led regional health system, submitted a mixed response to the proposed rule. | · | · | · | · | |
ENDOSPAN BusinessOppose Endospan, Ltd. | · | · | · | ||
Envoy Medical, Inc. BusinessOppose Envoy Medical, Inc. | · | · | · | ||
Epic Systems Corporation BusinessSupport Epic Systems Corporation supports the proposed updates to quality measurement, interoperability, and value-based care, b | · | · | · | · | · |
Epilepsy Foundation of America AdvocacyOppose The Epilepsy Foundation of America opposes the proposed repeal of the alternative pathway for new technology add-on paym | · | · | · | ||
Epiminder America Inc. BusinessOppose Epiminder America Inc. | · | · | · | · | · |
Essentia Health AdvocacyOppose Essentia Health, a healthcare system serving rural regions, opposes the proposed FY 2027 Medicare IPPS payment update as | · | · | · | · | |
Fairview Health Services BusinessOther Fairview Health Services, a nonprofit integrated health system, provides a mixed response to the proposed rule. | · | · | · | · | · |
Federation of American Hospitals AdvocacyOppose The Federation of American Hospitals (FAH) opposes the proposed CJR-X Model as a mandatory payment framework, arguing th | · | · | · | ||
Field Medical, Inc. BusinessOppose Field Medical, Inc., a medical device company, opposes the proposed elimination of the Alternative Pathways for New Tech | · | · | · | · | |
Firely USA Inc BusinessSupport Firely USA Inc., a health IT software company and FHIR standards expert, supports CMS's move toward digital quality meas | · | · | · | · | · |
Florida Hospital Association AdvocacyOppose The Florida Hospital Association (FHA) opposes the proposed rule, arguing that the FY 2027 inpatient payment updates are | · | · | · | · | · |
Francis Medical BusinessOppose Francis Medical, Inc. | · | · | · | ||
Gift of Hope Organ & Tissue Donor Network AdvocacyOppose Gift of Hope Organ & Tissue Donor Network, a non-profit organ procurement organization, opposes several provisions in th | · | · | · | · | · |
Gift of Life Donor Program AdvocacyOppose The Gift of Life Donor Program (GLDP), a non-profit organ procurement organization, opposes the proposed rule because it | · | · | · | · | · |
Gilead Sciences BusinessOppose Gilead Sciences, Inc. | · | · | · | ||
Hackensack Meridian Health AdvocacyOppose Hackensack Meridian Health opposes the proposed FY 2027 payment updates, arguing they do not sufficiently cover rising l | · | · | · | · | · |
Hall, Render, Killian, Heath & Lyman BusinessOppose Hall, Render, Killian, Heath & Lyman, P.C., a law firm representing approximately 300 hospitals, opposes the proposed ru | · | · | · | · | · |
Hall, Render, Killian, Heath & Lyman, P.C. AdvocacySupport Hall, Render, Killian, Heath & Lyman, P.C., representing over 400 hospitals, argues that CMS is unlawfully failing to re | · | · | · | · | · |
Harrison.ai BusinessOppose Harrison.ai, a diagnostic radiology solutions company, opposes the proposed elimination of alternative NTAP pathways tie | · | · | · | ||
Hartford Healthcare BusinessSupport Hartford Healthcare, a healthcare system in Connecticut, supports CMS's efforts to align payments with value and expand | · | · | · | · | · |
Healthcare Association of New York State AdvocacyOppose The Healthcare Association of New York State (HANYS) opposes several aspects of the proposed rule, specifically arguing | · | · | · | ||
Healthcare Information and Management Systems Society (HIMSS) AdvocacySupport The Healthcare Information and Management Systems Society (HIMSS) supports the proposed transition to digital quality me | · | · | · | · | · |
Henry Ford Health AdvocacyOppose Henry Ford Health, a large Michigan-based integrated health system, opposes several components of the proposed rule, inc | · | ||||
Heron Therapeutics AdvocacySupport Heron Therapeutics, a biotechnology company, argues that CMS should exclude drugs covered under the Non-Opioid Policy fo | · | · | · | · | · |
HFMA AdvocacyOther The Healthcare Financial Management Association (HFMA) submitted a comment expressing a mixed position on the proposed r | · | · | · | ||
Houston Methodist BusinessOther Houston Methodist, a healthcare system and academic medical center, submitted a mixed-position comment regarding the FY | · | · | · | ||
Impulse Dynamics, Inc. BusinessOppose Impulse Dynamics, a medical device manufacturer, opposes CMS's proposal to eliminate the Alternative Pathway for New Tec | · | · | · | · | |
Infectious Diseases Society of America AdvocacyOther The Infectious Diseases Society of America (IDSA) submitted a mixed-stance comment regarding the FY 2027 IPPS proposed r | · | · | · | · | |
Institute for Gene Therapies (IGT) AdvocacyOppose The Institute for Gene Therapies (IGT), a multi-stakeholder coalition, opposes the proposed repeal of the NTAP Alternati | · | · | · | · | |
Institute for Healthcare Improvement AdvocacySupport The Institute for Healthcare Improvement (IHI) supports the proposed modification to the Maternal Morbidity Structural M | · | · | · | · | · |
International Council on Active Aging AdvocacySupport The International Council on Active Aging (ICAA), a professional association representing the active-aging industry, sup | · | · | · | · | · |
International Society for the Advancement of Spine Surgery AdvocacyOther The International Society for Advancement of Spine Surgery (ISASS) submitted a mixed-stance comment regarding the propos | · | · | · | ||
Intuitive Surgical Inc. BusinessOppose Intuitive, a medical technology manufacturer, opposes the proposed elimination of the alternative New Technology Add-on | · | · | · | ||
Iowa Donor Network AdvocacyOppose The Iowa Donor Network (IDN), a nonprofit organ procurement organization, opposes the proposed changes to reimbursement | · | · | · | · | · |
Iowa Hospital Association AdvocacyOppose The Iowa Hospital Association opposes the proposed Medicare payment updates, arguing that the 1.3% increase for Iowa hos | · | · | · | · | |
Jefferson Health BusinessOppose Jefferson Health, a large integrated academic delivery and finance system, opposes several aspects of the proposed FY 20 | · | · | · | · | · |
Johns Hopkins Medicine > Emergency Medicine Operations Group AdvocacySupport The Emergency Medicine Owners Group (EMOG) supports the proposed measurement of emergency care access and timeliness but | · | · | · | · | · |
Johnson & Johnson BusinessOther Johnson & Johnson submitted comments regarding the FY 2027 IPPS proposed rule, expressing strong opposition to the repea | · | · | · | · | · |
Kansas Hospital Association AdvocacyOther The Kansas Hospital Association is submitting comments on behalf of its 124 member hospitals regarding the proposed FY 2 | · | · | · | ||
Keck Medicine of USC AdvocacyOppose Keck Medicine of USC opposes the proposed FY 2027 Medicare payment updates, arguing that the market basket increase and | · | · | |||
Kentucky Hospital Association AdvocacyOppose The Kentucky Hospital Association (KHA) opposes the proposed FY 2027 Medicare payment rates, arguing that the 2.4% incre | · | · | · | · | · |
King & Spalding, LLP BusinessOppose King & Spalding LLP, representing over 380 hospitals, opposes the proposed rule because it fails to restore payment rate | · | · | · | · | · |
Legacy Health BusinessOppose Legacy Health, a nonprofit healthcare provider, opposes several components of the proposed FY 2027 IPPS rule, specifical | · | · | · | · | |
Legacy of Hope AdvocacyOppose Legacy of Hope, an organ procurement organization (OPO), opposes the proposed reimbursement model for non-renal organs b | · | · | · | · | · |
Long Bridge Medical BusinessOppose Long Bridge Medical, Inc. | · | · | · | · | |
Louisiana Hospital Association AdvocacyOppose The Louisiana Hospital Association (LHA) opposes several components of the proposed FY 2027 IPPS and LTCH payment update | · | · | · | · | |
Louisiana Organ Procurement Agency AdvocacyOppose The Louisiana Organ Procurement Agency (LOPA) opposes the proposed rule's shift toward a fixed income or strictly cost-b | · | · | · | · | · |
Louisiana State Nurses Association AdvocacySupport The Louisiana State Nurses Association (LSNA) supports the proposed rule, specifically advocating for the inclusion of n | · | · | · | · | · |
Main Street Foundation Center for Regulatory Analysis and Engagement AdvocacySupport The Main Street Foundation’s Center for Regulatory Analysis and Engagement (CRAE) supports the proposed rule, specifical | · | · | · | · | · |
Massachusetts Health & Hospital Association AdvocacyOppose The Massachusetts Health & Hospital Association (MHA) opposes several aspects of the proposed FY 2027 IPPS rule, arguing | · | · | · | · | |
Mayo Clinic AdvocacyOther Mayo Clinic submitted a detailed comment expressing mixed positions on various components of the proposed rule. | · | · | · | · | · |
Medical Device Manufacturers Association (MDMA) AdvocacyOppose The Medical Device Manufacturers Association (MDMA) opposes the proposal to eliminate the Alternative Pathways for NTAP | · | · | · | ||
Medical Information Technology, Inc. BusinessOther MEDITECH, a healthcare technology company, provides mixed feedback on the proposed rule, supporting several measure alig | · | · | · | · | · |
Medtronic BusinessOppose Medtronic opposes the proposed repeal of the New Technology Add-on Payment (NTAP) and Outpatient Prospective Payment Sys | · | · | · | ||
Memorial Health System BusinessSupport Memorial Health System supports the inclusion of a Low Quartile Reclassification Mechanism in the FY 2027 IPPS/LTCH Prop | · | · | · | · | · |
Mental Health America AdvocacyOppose Mental Health America opposes CMS's proposal to disapprove New Technology Add-on Payments (NTAP) for the medication Cobe | · | · | · | · | · |
Mercy Health Ministry BusinessOther Mercy, a large healthcare system, submitted a mixed-position comment regarding the FY 2027 Hospital IPPS Proposed Rule. | · | · | · | · | |
Micro Medical Solutions BusinessOppose Micro Medical Solutions (MMS), a medical device company, opposes CMS's proposal to eliminate the Alternative Pathway for | · | · | · | · | |
Midwest Transplant Network, Inc. AdvocacyOppose Midwest Transplant Network, Inc. | · | · | · | · | · |
Minnesota Hospital Association AdvocacyOther The Minnesota Hospital Association (MHA) submitted comments expressing a mix of support and opposition regarding various | · | · | · | ||
Missouri Hospital Association AdvocacyOppose The Missouri Hospital Association opposes several components of the proposed rule, specifically the mandatory nature of | · | · | · | · | |
Moving Health Home AdvocacySupport Moving Health Home, a coalition of healthcare organizations, supports the proposed actions and urges CMS to further expa | · | · | · | · | · |
MultiCare Health System BusinessOppose MultiCare Health System, a hospital provider, opposes several aspects of the proposed FY 2027 IPPS rule, specifically th | · | · | · | · | |
National Alliance for Caregiving AdvocacySupport The National Alliance for Caregiving supports the expansion of the Comprehensive Care for Joint Replacement (CJR) Model | · | · | · | · | · |
National Association for Behavioral Healthcare AdvocacyOppose The National Association for Behavioral Healthcare opposes including the Emergency Care Access & Timeliness eCQM in the | · | · | · | · | · |
National Association of Long Term Hospitals AdvocacyOther The National Association of Long Term Hospitals (NALTH) submitted a mixed-position comment regarding the proposed FY 202 | · | · | · | · | |
National Comprehensive Cancer Network AdvocacySupport The National Comprehensive Cancer Network (NCCN) supports the adoption of new electronic clinical quality measures for A | · | · | · | · | · |
National Institute for Children's Health Quality AdvocacySupport The National Institute for Children's Health Quality (NICHQ) supports the proposal to require hospitals to identify spec | · | · | · | · | · |
National Rural Health Association AdvocacyOppose The National Rural Health Association (NRHA) opposes several proposed changes that they argue will disproportionately ha | · | · | · | · | |
Nebraska Medicine BusinessOther Nebraska Medicine, a non-profit academic medical system, submitted a mixed-stance comment regarding the FY2027 IPPS Prop | · | · | · | ||
NeuroPace, Inc. BusinessOppose NeuroPace, a medical device company, opposes the proposed elimination of the Alternative Pathway for New Technology Add- | · | · | · | ||
New Hampshire Hospital Association AdvocacyOther The New Hampshire Hospital Association (NHHA) provides a mixed response to the proposed rule, supporting updates to resi | · | · | · | · | · |
New Jersey Hospital Association AdvocacyOppose The New Jersey Hospital Association (NJHA) opposes the proposed FY 2027 Medicare payment updates, arguing that the marke | · | · | · | · | |
North Carolina Healthcare Association AdvocacyOppose The North Carolina Healthcare Association (NCHA) opposes the proposed FY 2027 Medicare payment updates, arguing that the | · | · | · | ||
North Memorial Health BusinessOppose North Memorial Health opposes several components of the proposed rule, specifically the mandatory implementation timelin | · | · | · | · | |
Northwell Health BusinessOther Northwell Health Systems, a large private health system, provides a mixed response to the proposed rule, agreeing with s | · | · | · | · | · |
Novant Health BusinessOther Novant Health, a healthcare network, provides mixed feedback on the proposed rule. | · | · | · | ||
OCHIN AdvocacySupport OCHIN, a nonprofit health IT organization, supports the proposed rule's goals of modernizing quality measurement and int | · | · | · | · | · |
Ohio Hospital Association AdvocacyOppose The Ohio Hospital Association (OHA) opposes the proposed FY 2027 IPPS rule, arguing that the 2.4% payment update is insu | · | · | · | ||
Olympus Corporation BusinessOppose Olympus Corporation of the Americas opposes the proposal to repeal alternative pathways for the New Technology Add-on Pa | · | · | · | ||
On Target Laboratories BusinessSupport On Target Laboratories, Inc. | · | · | · | · | · |
Optum BusinessSupport Optum (SCA Health) supports the proposal to allow physician-owned hospitals (POHs) to voluntarily opt into the Transform | · | · | · | · | · |
Organ Donation Advocacy Group (ODAG) AdvocacyOppose The Organ Donation Advocacy Group (ODAG), representing fourteen organ procurement organizations, opposes the proposed ch | · | · | · | · | · |
Partnership to Fight Infectious Disease AdvocacyOppose The Partnership to Fight Infectious Disease (PFID) opposes the proposal to repeal the alternative pathway for New Techno | · | · | · | · | |
Patients for Patient Safety US AdvocacySupport Patients for Patient Safety US (PFPS US), a patient-led advocacy organization, supports the majority of the proposed FY | · | · | · | · | · |
Penn Medicine AdvocacyOppose Penn Medicine, an academic medical center, opposes several components of the proposed FY 2027 IPPS rule, including the p | · | · | · | · | · |
Personalized Medicine Coalition AdvocacyOther The Personalized Medicine Coalition (PMC) provides a mixed response to the proposed rule, supporting the continuation of | · | · | · | · | |
PFPS-US AdvocacySupport Patients for Patient Safety US, a patient-led advocacy organization, expresses strong support for the proposed rule's sh | · | · | · | · | · |
Phelps Health BusinessOppose Phelps Health, a rural Sole Community Hospital, opposes the proposed rule because it fails to adequately account for the | · | · | · | · | |
Philips BusinessOppose Philips, a health technology company, opposes the proposed repeal of alternative New Technology Add-on Payment (NTAP) pa | · | · | · | · | · |
PhRMA AdvocacyOppose The Pharmaceutical Research and Manufacturers of America (PhRMA) opposes the proposed rule, specifically arguing that th | · | · | · | · | |
Premia Spine, Inc. BusinessOppose Premia Spine, Inc. | · | · | · | · | · |
Premier Inc. BusinessSupport Premier Inc., a healthcare improvement company and supply chain leader, supports the proposed FY 2027 IPPS rule but urge | · | · | · | ||
Providence AdvocacyOppose Providence, a nonprofit health system, opposes several aspects of the proposed rule, specifically arguing that the inpat | · | · | · | ||
Reflow Medical BusinessOppose Reflow Medical, the manufacturer of the Spur® Peripheral Retrievable Stent System, opposes the proposed elimination of t | · | · | · | ||
Reimbursement Insights LLC AdvocacyOppose Reimbursement Insights LLC, representing over 20 organ procurement organizations (OPOs) and histocompatibility labs, opp | · | · | · | · | · |
Rural WI Health Cooperative AdvocacyOppose The Rural Wisconsin Health Cooperative (RWHC), representing forty rural hospitals, opposes the proposed FY 2027 IPPS pay | · | · | · | · | · |
SafeHeal, Inc. BusinessOppose SafeHeal Inc., the manufacturer of the Colovac anastomosis protection device, opposes the proposed repeal of the NTAP al | · | · | · | ||
Safety Net Association of Pennsylvania AdvocacyOppose The Safety-Net Association of Pennsylvania (SNAP) opposes several components of the proposed FY 2027 Medicare IPPS regul | · | · | · | · | · |
Sentara Health BusinessOppose Sentara Health, a healthcare system, opposes several components of the proposed FY 2027 IPPS and LTCH PPS rules, specifi | · | · | · | · | · |
Sequana Medical NV BusinessOppose Sequana Medical NV, the manufacturer of the alfapump system, opposes the proposed elimination of alternative pathways fo | · | · | · | · | |
SGMC Health BusinessSupport South Georgia Medical Center, Inc. | · | · | · | · | · |
Shionogi Inc. BusinessOppose Shionogi Inc., a pharmaceutical company, opposes the proposed repeal of the alternative pathway for New Technology Add-o | · | · | · | · | |
Shiratronics, Inc. BusinessOppose ShiraTronics, Inc. | · | · | · | · | |
SI-BONE, Inc. BusinessSupport SI-BONE, Inc., a medical device manufacturer, supports the creation of new MS-DRGs (523, 524, and 525) for complex spina | · | · | · | · | · |
Singing River Health System BusinessSupport Singing River Health System supports the proposed Low Quartile Reclassification Mechanism and advocates for specific ref | · | · | · | · | · |
Smith & Nephew BusinessSupport Smith+Nephew, a medical technology company, supports the proposed bundled payment models and the implementation of the H | · | · | · | ||
Society for Cardiovascular Angiography and Interventions AdvocacyOther The Society for Cardiovascular Angiography and Interventions (SCAI) expresses support for the approval of numerous new t | · | · | · | ||
Solaris Endovascular Inc. BusinessOppose Solaris Endovascular, Inc., a medical device company, opposes the proposed elimination of the NTAP and TPT pathways for | · | · | · | · | |
Spryte Medical, Inc. BusinessOppose Spryte Medical, a medical device startup, opposes the proposed repeal of the alternative New Technology Add-on Payment ( | · | · | · | ||
Suburban Hospital Alliance of NYS AdvocacyOppose The Suburban Hospital Alliance of New York State opposes the proposed FY 2027 IPPS payment updates, arguing that the 3.2 | · | · | · | · | · |
Sutter Health BusinessOther Sutter Health, a non-profit healthcare system, submitted a mixed-position comment regarding the FY 2027 IPPS and LTCH pr | · | · | · | · | |
Tennessee Hospital Association AdvocacyOppose The Tennessee Hospital Association (THA) opposes several components of the proposed FY 2027 IPPS and LTCH rules, specifi | · | · | · | ||
Texas Health Resources BusinessSupport Texas Health Resources, a large faith-based nonprofit healthcare system, supports the proposed FY 2027 IPPS updates and | · | · | · | · | |
Texas Hospital Association Trade associationOppose The Texas Hospital Association (THA) opposes the proposed market basket update and productivity adjustments, arguing the | · | · | |||
The American Association of Pro-Life Obstetricians and Gynecologists (AAPLOG) AdvocacySupport The American Association of Pro-Life Obstetricians and Gynecologists (AAPLOG) supports the proposed rule's anti-discrimi | · | · | · | · | · |
The Health Care Transformation Task Force (NCTTF) AdvocacySupport The Health Care Transformation Task Force (HCTTF), a non-profit collaborative representing various healthcare stakeholde | · | · | · | · | · |
The Hospital and Healthsystem Association of Pennsylvania AdvocacyOppose The Hospital and Healthsystem Association of Pennsylvania (HAP) opposes the proposed FY 2027 IPPS payment update, arguin | · | · | · | · | · |
The New England Medical Innovation Center (NEMIC) AdvocacyOppose The New England Medical Innovation Center (NEMIC), a nonprofit hub for medical technology, opposes the proposal to elimi | · | · | · | ||
The University of Pittsburgh Medical Center AdvocacyOppose The University of Pittsburgh Medical Center (UPMC) opposes the proposed 2.4% IPPS payment rate update for FY 2027, argui | · | · | · | · | · |
Trinity Health AdvocacyOppose Trinity Health, a large non-profit Catholic health care system, opposes several components of the proposed FY2027 IPPS r | · | · | · | ||
Tufts Medicine AdvocacyOppose Tufts Medicine, a Massachusetts-based health system, opposes the proposed 2.4% payment update as insufficient to cover r | · | · | · | ||
UnityPoint Health BusinessOther UnityPoint Health, a large integrated healthcare system, provides a mixed response to the proposed rule. | · | · | · | · | |
University of Colorado Health (UCHealth) BusinessSupport UCHealth, a healthcare organization, supports the proposed changes to the Promoting Interoperability Program but request | · | · | · | · | · |
University of Iowa HealthCare AdvocacyOppose University of Iowa Health Care, representing an academic medical center, opposes several components of the FY 2027 IPPS | · | · | · | · | |
University of Vermont Health AdvocacyOther University of Vermont Health (UVM Health) submitted comments regarding the FY 2027 IPPS proposed rule, expressing concer | · | · | · | · | |
Versiti Blood Health, Inc. AdvocacyOppose Versiti Blood Health, Inc., a nonprofit organ procurement organization, opposes the proposed expansion of renal organ ac | · | · | · | · | |
Vertex Pharmaceuticals BusinessOppose Vertex Pharmaceuticals Incorporated opposes several proposed changes to the New Technology Add-on Payment (NTAP) program | · | · | · | · | |
Vessi Medical Ltd. BusinessOppose Vessi Medical Ltd., a medical device company, opposes the proposed repeal of the "Alternative Pathway" for New Technolog | · | · | · | ||
Vizient, inc. AdvocacyOther Vizient, Inc., a healthcare performance improvement company, provides a mixed response to the proposed rule, offering se | · | · | · | ||
VS3 Medical, Inc BusinessOppose VS3 Medical, a medical technology company developing a treatment for pulsatile tinnitus, opposes CMS's proposal to elimi | · | · | · | · | |
Vuno BusinessOppose VUNO Med Inc., the manufacturer of DeepCARS®, opposes CMS's proposal to repeal the alternative pathway for New Technolog | · | · | · | ||
Washington State Hospital Association AdvocacyOppose The Washington State Hospital Association opposes the proposed rule, arguing that the market basket update is too low to | · | · | · | · | · |
Wellsense, Inc BusinessSupport Wellsense, Inc. | · | · | · | · | · |
WellSpan Health BusinessOther WellSpan Health, a regional healthcare provider, expresses concern that the proposed Medicare reimbursement updates are | · | · | · | · | |
Wisconsin Hospital Association AdvocacyOppose The Wisconsin Hospital Association (WHA) opposes several components of the proposed rule, specifically the rapid, retroa | · | · | · | · | |
Wockhardt Bio AG BusinessOppose Wockhardt Bio AG, a pharmaceutical and biotechnology company, opposes the proposal to repeal the alternative pathway for | · | · | · | · |
Abbott
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Abridge
AdvocacySupport
Adagio Medical, Inc.
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
AdvaMed
AdvocacyOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
AdventHealth
AdvocacySupport
Adventist Health
AdvocacyOppose
Adventist Health Policy Association
AdvocacySupport
Advocate Health
AdvocacyOther
Methodology and risk adjustment
Impact on rural healthcare access
AgNovos Bioscience, Inc.
BusinessSupport
AHIP
AdvocacySupport
Alabama Hospital Association
AdvocacyOther
Impact on rural healthcare access
Alliance for Patient Access
AdvocacySupport
Repeal of ntap alternative pathway
Alliance of Safety-Net Hospitals
AdvocacyOppose
Alliance on Hospital Reimbursement
AdvocacyOppose
Impact on rural healthcare access
Inadequate ipps payment rate increase
Allina Health
AdvocacyOppose
Inadequate ipps payment rate increase
Altera Digital Health
AdvocacyOther
America's Essential Hospitals
AdvocacyOppose
American Academy of Hospice and Palliative Medicine
AdvocacySupport
American Association of Hip and Knee Surgeons
AdvocacyOppose
Impact on rural healthcare access
American Association of Neurological Surgeons / Congress of Neurological Surgeons
AdvocacySupport
American Association of Orthopaedic Surgeons
AdvocacyOppose
American College of Cardiology
AdvocacyOther
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
American College of Obstetricians & Gynecologists
AdvocacyOther
Impact on rural healthcare access
American College of Surgeons
AdvocacyOther
Impact on rural healthcare access
American Diabetes Association
AdvocacyOther
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
American Hospital Association
AdvocacyOppose
Impact on rural healthcare access
American Medical Association
AdvocacyOther
American Pharmacists Association
AdvocacyOppose
American Society for Transplantation and Cellular Therapy
AdvocacyOther
AMGA
AdvocacyOther
Amgen, Inc.
BusinessSupport
Repeal of ntap alternative pathway
AQUAPASS, Inc
BusinessOppose
Repeal of ntap alternative pathway
Arboretum Ventures
AdvocacyOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Arthrex, Inc.
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Ascension
AdvocacyOther
Methodology and risk adjustment
Impact on rural healthcare access
Association for Health Care Resource & Materials Management of the American Hospital Association
AdvocacySupport
Association of Organ Procurement Organizations
AdvocacyOppose
Impact on rural healthcare access
Association of periOperative Registered Nurses
AdvocacySupport
Aveera Medical, Inc.
BusinessOppose
Breakthrough device alternative pathways
Basilea Pharmaceitica International Ltd.
BusinessOppose
Repeal of ntap alternative pathway
BayCare Health System
BusinessOther
Inadequate ipps payment rate increase
BEAM Alliance
AdvocacyOppose
Repeal of ntap alternative pathway
Becton, Dickinson and Company (BD)
AdvocacyOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Billings Clinic Logan Health
BusinessOppose
Inadequate ipps payment rate increase
BJC Health
BusinessSupport
Methodology and risk adjustment
Blue Cross Blue Shield Association (BCBSA)
AdvocacySupport
BONESUPPORT, Inc.
BusinessSupport
Breakthrough device alternative pathways
Boston Scientific Corporation
BusinessOppose
Breakthrough device alternative pathways
Bristol Myers Squibb
AdvocacySupport
Bruin Biometrics, LLC
BusinessSupport
Breakthrough device alternative pathways
Cascade Life Alliance
AdvocacyOppose
Impact on rural healthcare access
Catholic Health Association of the United States
AdvocacyOther
Inadequate ipps payment rate increase
CellTrans Inc
BusinessOther
CentraCare Health
BusinessSupport
Methodology and risk adjustment
Ceribell
AdvocacyOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Cleveland Clinic
BusinessOppose
Coalition of Long-Term Acute-Care Hospitals
AdvocacyOppose
Methodology and risk adjustment
Coalition to Transform Advanced Care
AdvocacySupport
Confluence Health
BusinessOppose
Connected Health Initiative
AdvocacySupport
Connecticut Hospital Association
AdvocacyOther
Methodology and risk adjustment
Impact on rural healthcare access
Inadequate ipps payment rate increase
ConnectLife
AdvocacyOppose
Cook Group, Inc.
AdvocacyOther
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Cordis
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Covisus Inc.
AdvocacyOther
Danaher
AdvocacySupport
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Denver Health and Hospital Authority
AdvocacyOppose
Methodology and risk adjustment
Dialysis Vascular Access Coalition
AdvocacyOther
Digital Quality Implementers Community (facilitated by Leavitt Partners
AdvocacySupport
Donor Network of Arizona
AdvocacyOppose
Donor Network West
AdvocacyOppose
Duke-Margolis Institute for Health Policy
AdvocacySupport
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
EBR
BusinessSupport
Edgewood Surgical Hospital
BusinessSupport
Emplify Health
AdvocacyOther
Methodology and risk adjustment
ENDOSPAN
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Envoy Medical, Inc.
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Epic Systems Corporation
BusinessSupport
Epilepsy Foundation of America
AdvocacyOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Epiminder America Inc.
BusinessOppose
Essentia Health
AdvocacyOppose
Methodology and risk adjustment
Fairview Health Services
BusinessOther
Federation of American Hospitals
AdvocacyOppose
Impact on rural healthcare access
Inadequate ipps payment rate increase
Field Medical, Inc.
BusinessOppose
Breakthrough device alternative pathways
Firely USA Inc
BusinessSupport
Florida Hospital Association
AdvocacyOppose
Francis Medical
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Gift of Hope Organ & Tissue Donor Network
AdvocacyOppose
Gift of Life Donor Program
AdvocacyOppose
Gilead Sciences
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Hackensack Meridian Health
AdvocacyOppose
Hall, Render, Killian, Heath & Lyman
BusinessOppose
Hall, Render, Killian, Heath & Lyman, P.C.
AdvocacySupport
Harrison.ai
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Hartford Healthcare
BusinessSupport
Healthcare Association of New York State
AdvocacyOppose
Methodology and risk adjustment
Inadequate ipps payment rate increase
Healthcare Information and Management Systems Society (HIMSS)
AdvocacySupport
Henry Ford Health
AdvocacyOppose
Breakthrough device alternative pathways
Methodology and risk adjustment
Impact on rural healthcare access
Inadequate ipps payment rate increase
Heron Therapeutics
AdvocacySupport
HFMA
AdvocacyOther
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Houston Methodist
BusinessOther
Breakthrough device alternative pathways
Inadequate ipps payment rate increase
Impulse Dynamics, Inc.
BusinessOppose
Breakthrough device alternative pathways
Infectious Diseases Society of America
AdvocacyOther
Repeal of ntap alternative pathway
Institute for Gene Therapies (IGT)
AdvocacyOppose
Repeal of ntap alternative pathway
Institute for Healthcare Improvement
AdvocacySupport
International Council on Active Aging
AdvocacySupport
International Society for the Advancement of Spine Surgery
AdvocacyOther
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Intuitive Surgical Inc.
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Iowa Donor Network
AdvocacyOppose
Iowa Hospital Association
AdvocacyOppose
Methodology and risk adjustment
Jefferson Health
BusinessOppose
Johns Hopkins Medicine > Emergency Medicine Operations Group
AdvocacySupport
Johnson & Johnson
BusinessOther
Kansas Hospital Association
AdvocacyOther
Impact on rural healthcare access
Inadequate ipps payment rate increase
Keck Medicine of USC
AdvocacyOppose
Repeal of ntap alternative pathway
Methodology and risk adjustment
Inadequate ipps payment rate increase
Kentucky Hospital Association
AdvocacyOppose
King & Spalding, LLP
BusinessOppose
Legacy Health
BusinessOppose
Methodology and risk adjustment
Legacy of Hope
AdvocacyOppose
Long Bridge Medical
BusinessOppose
Breakthrough device alternative pathways
Louisiana Hospital Association
AdvocacyOppose
Impact on rural healthcare access
Louisiana Organ Procurement Agency
AdvocacyOppose
Louisiana State Nurses Association
AdvocacySupport
Main Street Foundation Center for Regulatory Analysis and Engagement
AdvocacySupport
Massachusetts Health & Hospital Association
AdvocacyOppose
Breakthrough device alternative pathways
Mayo Clinic
AdvocacyOther
Medical Device Manufacturers Association (MDMA)
AdvocacyOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Medical Information Technology, Inc.
BusinessOther
Medtronic
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Memorial Health System
BusinessSupport
Mental Health America
AdvocacyOppose
Mercy Health Ministry
BusinessOther
Inadequate ipps payment rate increase
Micro Medical Solutions
BusinessOppose
Breakthrough device alternative pathways
Midwest Transplant Network, Inc.
AdvocacyOppose
Minnesota Hospital Association
AdvocacyOther
Breakthrough device alternative pathways
Methodology and risk adjustment
Missouri Hospital Association
AdvocacyOppose
Inadequate ipps payment rate increase
Moving Health Home
AdvocacySupport
MultiCare Health System
BusinessOppose
Inadequate ipps payment rate increase
National Alliance for Caregiving
AdvocacySupport
National Association for Behavioral Healthcare
AdvocacyOppose
National Association of Long Term Hospitals
AdvocacyOther
Methodology and risk adjustment
National Comprehensive Cancer Network
AdvocacySupport
National Institute for Children's Health Quality
AdvocacySupport
National Rural Health Association
AdvocacyOppose
Methodology and risk adjustment
Nebraska Medicine
BusinessOther
Repeal of ntap alternative pathway
Methodology and risk adjustment
NeuroPace, Inc.
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
New Hampshire Hospital Association
AdvocacyOther
New Jersey Hospital Association
AdvocacyOppose
Inadequate ipps payment rate increase
North Carolina Healthcare Association
AdvocacyOppose
Impact on rural healthcare access
Inadequate ipps payment rate increase
North Memorial Health
BusinessOppose
Methodology and risk adjustment
Northwell Health
BusinessOther
Novant Health
BusinessOther
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
OCHIN
AdvocacySupport
Ohio Hospital Association
AdvocacyOppose
Methodology and risk adjustment
Impact on rural healthcare access
Olympus Corporation
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
On Target Laboratories
BusinessSupport
Optum
BusinessSupport
Organ Donation Advocacy Group (ODAG)
AdvocacyOppose
Partnership to Fight Infectious Disease
AdvocacyOppose
Repeal of ntap alternative pathway
Patients for Patient Safety US
AdvocacySupport
Penn Medicine
AdvocacyOppose
Personalized Medicine Coalition
AdvocacyOther
Breakthrough device alternative pathways
PFPS-US
AdvocacySupport
Phelps Health
BusinessOppose
Impact on rural healthcare access
Philips
BusinessOppose
PhRMA
AdvocacyOppose
Repeal of ntap alternative pathway
Premia Spine, Inc.
BusinessOppose
Premier Inc.
BusinessSupport
Methodology and risk adjustment
Impact on rural healthcare access
Providence
AdvocacyOppose
Methodology and risk adjustment
Inadequate ipps payment rate increase
Reflow Medical
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Reimbursement Insights LLC
AdvocacyOppose
Rural WI Health Cooperative
AdvocacyOppose
SafeHeal, Inc.
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Safety Net Association of Pennsylvania
AdvocacyOppose
Sentara Health
BusinessOppose
Sequana Medical NV
BusinessOppose
Breakthrough device alternative pathways
SGMC Health
BusinessSupport
Shionogi Inc.
BusinessOppose
Repeal of ntap alternative pathway
Shiratronics, Inc.
BusinessOppose
Breakthrough device alternative pathways
SI-BONE, Inc.
BusinessSupport
Singing River Health System
BusinessSupport
Smith & Nephew
BusinessSupport
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Society for Cardiovascular Angiography and Interventions
AdvocacyOther
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Solaris Endovascular Inc.
BusinessOppose
Breakthrough device alternative pathways
Spryte Medical, Inc.
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Suburban Hospital Alliance of NYS
AdvocacyOppose
Sutter Health
BusinessOther
Breakthrough device alternative pathways
Tennessee Hospital Association
AdvocacyOppose
Methodology and risk adjustment
Impact on rural healthcare access
Texas Health Resources
BusinessSupport
Inadequate ipps payment rate increase
Texas Hospital Association
Trade associationOppose
Methodology and risk adjustment
Impact on rural healthcare access
Inadequate ipps payment rate increase
The American Association of Pro-Life Obstetricians and Gynecologists (AAPLOG)
AdvocacySupport
The Health Care Transformation Task Force (NCTTF)
AdvocacySupport
The Hospital and Healthsystem Association of Pennsylvania
AdvocacyOppose
The New England Medical Innovation Center (NEMIC)
AdvocacyOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
The University of Pittsburgh Medical Center
AdvocacyOppose
Trinity Health
AdvocacyOppose
Methodology and risk adjustment
Inadequate ipps payment rate increase
Tufts Medicine
AdvocacyOppose
Methodology and risk adjustment
Inadequate ipps payment rate increase
UnityPoint Health
BusinessOther
Impact on rural healthcare access
University of Colorado Health (UCHealth)
BusinessSupport
University of Iowa HealthCare
AdvocacyOppose
Breakthrough device alternative pathways
University of Vermont Health
AdvocacyOther
Methodology and risk adjustment
Versiti Blood Health, Inc.
AdvocacyOppose
Impact on rural healthcare access
Vertex Pharmaceuticals
BusinessOppose
Repeal of ntap alternative pathway
Vessi Medical Ltd.
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Vizient, inc.
AdvocacyOther
Repeal of ntap alternative pathway
Impact on rural healthcare access
VS3 Medical, Inc
BusinessOppose
Breakthrough device alternative pathways
Vuno
BusinessOppose
Breakthrough device alternative pathways
Repeal of ntap alternative pathway
Washington State Hospital Association
AdvocacyOppose
Wellsense, Inc
BusinessSupport
WellSpan Health
BusinessOther
Methodology and risk adjustment
Wisconsin Hospital Association
AdvocacyOppose
Inadequate ipps payment rate increase
Wockhardt Bio AG
BusinessOppose
Repeal of ntap alternative pathway
11 organization-typed comments could not be identified.
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- Jun 9, 2026Pfizer, Inc.OpposeBusiness📎 Attachment
Pfizer, Inc. opposes several components of the proposed rule, specifically the repeal of NTAP alternative pathways for certain drugs and devices, the shortening of the NTAP newness period, and the removal of COVID-19 vaccination quality measures. The company argues that these changes would create unnecessary regulatory burdens, undermine data integrity for rate-setting, and reduce protections for high-risk patient populations.
Read comment → - Jun 9, 2026Shionogi Inc.OpposeBusiness📎 Attachment
Shionogi Inc., a pharmaceutical company, opposes the proposed repeal of the alternative pathway for New Technology Add-on Payments (NTAP) for certain antimicrobial products. The company argues that the current pathway is necessary to address the public health threat of antimicrobial resistance and that the proposed requirements for "substantial clinical improvement" are difficult to meet due to the unique clinical trial designs required for antibiotics.
Read comment → - Jun 9, 2026Partnership to Fight Infectious DiseaseOpposeAdvocacy📎 Attachment
The Partnership to Fight Infectious Disease (PFID) opposes the proposal to repeal the alternative pathway for New Technology Add-on Payment (NTAP) applications for Qualified Infectious Disease Products (QDIPS). They argue that the proposed change creates an impossible and unethical clinical trial standard for antibiotics and will stifle the development of new treatments needed to combat antibiotic resistance.
Read comment → - Jun 9, 2026UCSF Team for High-Value CareSupportAdvocacy📎 Attachment
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.
Read comment → - Jun 9, 2026Amgen, Inc.SupportBusiness📎 Attachment
Amgen, a pharmaceutical company, supports the CMS proposal to continue New Technology Add-on Payment (NTAP) status for its drug IMDELLTRA for fiscal year 2027. The company argues that the drug remains "new" under current Medicare policy and that continued NTAP status is necessary to ensure patient access to this treatment for small cell lung cancer.
Read comment → - Jun 9, 2026Alliance for Patient AccessSupportAdvocacy📎 Attachment
The Alliance for Patient Access, a national network of healthcare providers, supports the approval of the New Technology Add-On Payment for xanomeline and trospium chloride (Cobenfy). They argue that the drug provides a critical new mechanism of action for treating schizophrenia with fewer side effects—such as weight gain and tardive dyskinesia—compared to current standard-of-care antipsychotics.
Read comment → - Jun 9, 2026MASSACHUSETTS MEDICAL DEVICE INDUSTRY COUNCILOpposeTrade association📎 Attachment
The Massachusetts Medical Device Industry Council (MassMEDIC) opposes the proposed repeal of the alternative NTAP and OPPS TPT pathways for FDA-designated Breakthrough Devices. They argue that these pathways are essential for providing predictable reimbursement for innovative technologies, and that an abrupt repeal will stifle investment, harm small manufacturers, and delay patient access to life-saving treatments.
Read comment → - Jun 9, 2026SpinaFxOpposeBusiness
SpinaFx, a medical device manufacturer, opposes the proposal to dissolve the Alternative Pathway for FDA Designated Breakthrough Devices under the hospital outpatient Transitional Pass Through. The company argues that removing this pathway creates uncertainty for new technologies and requests at least a two-year delay to allow devices in the pipeline sufficient time to complete their submissions.
Read comment → - Jun 9, 2026BIOOpposeAdvocacy📎 Attachment
The Biotechnology Innovation Organization (BIO) opposes the proposed repeal of the New Technology Add-on Payment (NTAP) alternative pathway, arguing it will create barriers to patient access for innovative therapies and increase costs for manufacturers. They also request that CMS develop new mechanisms, such as unbundling drugs or creating a low-volume/orphan drug add-on payment, to ensure sustainable reimbursement for rare disease treatments within the MS-DRG structure.
Read comment → - Jun 9, 2026Alliance for Regenerative MedicineOpposeAdvocacy📎 Attachment
The Alliance for Regenerative Medicine (ARM) opposes several key provisions of the proposed rule, specifically the repeal of the NTAP alternative pathway, the constriction of "commercial availability" delays, and the adoption of a cross-modality comparator approach for substantial clinical improvement. The organization argues that these changes would create significant barriers to patient access for cell and gene therapies (CGTs) and undermine the U.S. position in the regenerative medicine sector.
Read comment →