Comment on CMS-2026-1256-0002

Summary: AdventHealth, a national non-profit healthcare system, generally supports the proposed FY 2027 IPPS updates, including the CJR-X and TEAM models, but requests specific refinements to ensure operational feasibility. They advocate for clearer overlap rules, more nuanced quality measures, and the restoration of Section 1115 waiver days in Medicare DSH calculations to protect hospitals serving vulnerable populations.