Comment on CMS-2026-1916-0001

Summary: The Adventist Health Policy Association (AHPA), representing five affiliated health systems, opposes the proposed rule because it exceeds the statutory scope of Public Law 119-21, increases administrative burdens, and risks reducing access to care. They argue that the proposed Medicare-based payment limits are too rigid and complex, and they urge CMS to limit restrictions to the four categories identified by Congress while preserving state flexibility and existing payment methodologies.