Comment on CMS-2026-1256-0002

Summary: The Adventist Health Policy Association (AHPA), representing a large network of health systems, generally supports the proposed FY 2027 IPPS updates and value-based care models like CJR-X and TEAM. However, they request specific refinements to ensure operational feasibility, including clearer overlap rules, more nuanced quality measures for sepsis and joint replacements, and the restoration of Section 1115 waiver days in DSH calculations.