Comment on CMS-2026-1916-0001

Summary: The Alliance of Safety-Net Hospitals (ASH) opposes the proposed rule, arguing that it exceeds statutory authority and would restrict states' ability to provide adequate Medicaid funding to safety-net hospitals. They specifically urge CMS to limit Medicare-based caps to the four categories identified by Congress, preserve state flexibility for uniform rate increases, and use an aggregate rather than hospital-specific payment limit methodology.