The AAMC submitted June 10 comments (PDF) in response to the Centers for Medicare & Medicaid Services (CMS) Fiscal Year (FY) 2026 Inpatient Prospective Payment System (IPPS) proposed rule [refer to Washington Highlights, April 18].
Among the comments provided to the agency, the AAMC asked for an increase to the market basket update to account for increased supply and input costs, citing in particular the expected rise in costs stemming from tariffs. Comments also touched on disproportionate share hospital and uncompensated care payments, the low wage index policy including the transition policy, and additional transparency in the labor-related share.
The AAMC thanked the CMS for providing clarification and public inspection of its longstanding policy for full-time equivalency determinations in cost reporting periods other than twelve months.
Regarding hospital quality programs, the AAMC urged the agency not to introduce unfair measurement and payment bias into the Hospital Readmissions Reduction Program and to ensure that new measures are endorsed by a consensus-based entity as valid and reliable and that they meet the needs of patients, families, and communities to inform their decisions on where to seek high-quality care.
The comments provided details on the proposals for the Transforming Episodic Accountability Model, including asking the CMS to ensure adequate risk adjustment, establish a low-volume threshold with no downside financial risk, implement a consistent, well-tested set of quality metrics for the duration of the model, and refine the primary care referral requirement to improve patient access to care and outcomes.
The AAMC also responded to a request for information on Unleashing Prosperity Through Deregulation of the Medicare Program (PDF), providing specific recommendations on streamlining regulatory requirements, reducing administrative burden of reporting and documentation, and identifying duplicative requirements in the Medicare program.