28 May The Task Force Provides Input to CMS on the CY 2026 Inpatient Prospective Payment Systems Proposed Rule
Posted at 09:50h
in Policy Communications
The Health Care Transformation Task Force submitted comments on the Centers for Medicare & Medicaid Services (CMS) CY 2026 Inpatient Prospective Payment System (IPPS) Proposed Rule (CMS-1833-P). The Task Force’s letter focused on the following:
- Transforming Episode Accountability Model (TEAM)
- Participation Options: The Task Force supports CMS’ decision to offer rural and safety net hospitals three years without downside risk. We also appreciate that these hospitals will be offered lower financial risk in Track 2, although we remain concerned that this financial risk may still cause harm to some hospitals.
- Episode Definitions: The Task Force believes the minimum viable option for the low-volume threshold is 31 episodes in the baseline for each clinical episode (rather than all clinical episodes in aggregate). The Task Force also supports CMS offering hospitals upside-only risk on episodes below this threshold.
- Quality Measurement: The Task Force recommends that CMS consider the use of an alternative Inpatient Quality Reporting (IQR) measure, specifically the THA/TKA PRO-PM. This measure reflects clinical outcomes as well as patient experience.
- Target Price Methodology: The Task Force is generally supportive of the technical adjustments to the target price methodology and risk adjustment. However, we recommend CMS apply the setting-specific update factor in response to coding changes during the model as they did under BPCIA.
- Care Delivery: The Task Force supports the Skilled Nursing Facility waiver and believes that CMS should further expand the waivers available under TEAM. The Task Force also supports CMS’ proposal to require hospitals to connect patients to their primary care physician prior to discharge.
- Value-based Care Policies Impacting Hospitals
- Inpatient VBC Policies: The Task Force supports CMS’ proposal to include MA patients in the IQR measures.
- Interoperability: The Task Force supports CMS’ proposals related to interoperability.
- Digital Quality Measurement Request for Information: The Task Force has concerns that the move to electronic Clinical Quality Measures adoption is weakening incentives to participate in the Shared Savings Program. The large financial outlay and operational complexity of implementing these measures is already impacting ACO network participation decisions.