HFMA Comments on the FY 2027 Hospital IPPS and LTCH Proposed Rule

In a June 9, 2026, letter to CMS, HFMA submitted comments pertaining to Proposed Rule CMS-1849-P Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital Proposed Rule and Other Revisions for FY 2027. HFMA evaluates all payment proposals against its five principles of an effective payment system: quality, alignment of incentives, fairness and sustainability, simplification, and societal benefit. HFMA supports several proposals in the rule that promote access, alignment, and administrative relief. In particular, it supports:

• Reduced reporting burden through measure removals and interoperability changes.
• Recognition of advance care planning as an important quality domain.
• Greater clarity around organ acquisition cost reimbursement.

HFMA supports CMS’s continued efforts to advance value-based care, improve quality, and promote innovation across Medicare programs. At the same time, hospitals and health systems continue to face significant financial, operational, and workforce challenges. To ensure providers can continue delivering high-quality care while successfully participating in Medicare programs, HFMA urges CMS to prioritize the following recommendations across the FY 2027 proposed rules:

• Increase FY 2027 Payment Updates to Better Reflect Actual Provider Cost Inflation
• Retain the Alternative NTAP Pathway for FDA Breakthrough Devices
• Support Extension of the Medicare-Dependent Hospital (MDH) Program
• Modify CJR-X to Reduce Administrative Burden and Provider Financial Risk
• Revise IRF Therapy Initiation Requirements to Preserve Physician Clinical Judgment