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AHPA submitted comments on: CMS-1833-P; Medicare Program; Hospital Inpatient Prospective Payment Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective Payment System and Policy Changes and Fiscal Year 2026 Rates; Requirements for Quality Programs; and Other Policy Changes. Click here for the full comment letter. Below are some key takeaways.

• Update Medicare hospital payments to more accurately reflect the cost of care: AHPA recommends that CMS incorporate additional data into the IPPS market basket, particularly actual expenses associated with contract and contingent labor, rather than relying primarily on estimated labor costs. It also supports transitional relief for low-wage hospitals, provided that the policy remains non-budget neutral and does not reduce payments to other hospitals.
• Provide greater flexibility and fairer requirements under the mandatory TEAM model: AHPA recommends expanding access to TEAM data, providing new hospitals with performance data during their participation grace period, and protecting certain Medicare-dependent hospitals’ access to more flexible participation tracks. It also calls for a 12-month risk-adjustment lookback, protections for low-volume hospitals, standardized costs for comparisons, and clear requirements for patient-reported outcome measures and primary care referrals.
• Modernize hospital quality reporting while retaining useful health-related data: AHPA supports including Medicare Advantage patients in certain quality measures, shortening performance periods so results reflect more recent care, and lowering electronic data-submission thresholds. It also supports removing low-value structural and COVID-19 vaccination measures. However, AHPA recommends retaining voluntary reporting of social drivers of health data to support standardized research and community health policymaking.
• Avoid quality and interoperability requirements that do not directly reflect patient care: AHPA opposes tying hospitals’ annual payment updates to their ability to submit technical electronic data because this does not directly measure care quality. It also recommends placing future well-being and nutrition measures in outpatient programs rather than inpatient reporting and favors practical cybersecurity guidance over an additional attestation requirement that may not meaningfully prevent attacks.
• Reduce duplicative administrative requirements and preserve patient-access flexibilities: AHPA recommends simplifying Medicare notices, reforming prior authorization, improving Medicare Advantage payment transparency, clarifying home health rules, and eliminating duplicative documentation. It also supports permanently eliminating the skilled nursing facility three-day stay requirement, maintaining telehealth and Hospital at Home flexibilities, improving provider privacy, and modernizing regulations governing emergency care, laboratories, and health data interoperability.