Comment on CMS-2026-1256-0002

Summary: BayCare Health System, a non-profit healthcare provider, argues that the proposed 2.4% payment update fails to keep pace with actual hospital cost growth, particularly regarding labor and supplies. The organization also requests the revocation of a rule excluding uncompensated care pool patients from the DSH Medicaid Fraction and expresses concerns regarding the episode length and measurement specifications of several new value-based care models.