Premier Submits Comments on Medicare Hospital Inpatient and Skilled Nursing Facility Proposed Rules

Premier submitted comments on the fiscal year (FY) 2026 Inpatient Prospective Payment System (IPPS) and Skilled Nursing Facility (SNF) PPS proposed rules.

In its comments in response to the IPPS proposed rule, Premier urges CMS to:

• Enhance the market basket update to reflect the impact of labor expenses, inflation and other exogenous influences and consider new or supplemental data sources to ensure labor costs are adequately reflected in the Medicare hospital payment;
• Solicit input from the hospital community on reforms to the wage index and efforts to improve the sustainability of workforce, especially in rural communities;
• Make refinements to the Transforming Episode Accountability Model (TEAM) to ensure the model is a success for hospitals, CMS and Medicare beneficiaries by:

• Permitting all participating hospitals to also be eligible for Track 1 in their first performance year, regardless of when they join TEAM;

• Extend the TEAM lookback period for evaluating Hierarchical Condition Category (HCC) counts for purposes of risk adjustment from 180 days to one year, which would align with the Comprehensive Care for Joint Replacement (CJR) model;

• Allow the TEAM episode end date to determine attribution of baseline episodes and performance year episodes;

• Set the TEAM low-volume threshold as 40 episodes per episode category during the baseline period, and either exclude or subject to Track 1 hospitals that meet the low-volume threshold; and

• Add a “Standard User” role in the CMS data portal that allows the participant data custodian to approve data access for analytical support.

• Avoid retroactive effective dates when proposing to remove quality measures from quality reporting programs, especially for relatively new measures; and
• Convene stakeholders and subject matter experts to assess whether the querying of Prescription Drug Monitoring Programs (PDMPs) has the intended effect of lowering overprescription of opioids before investing more time and money into a new performance-based measure.

In its comments in response to the SNF proposed rule, Premier recommends that CMS:

• Develop a process and methodology that directly and accurately captures wage costs;
• Advance a comprehensive approach to the transfer of health information by focusing on additional efforts for interoperability across the care continuum, including SNFs, via electronic data exchange;
• Incentivize SNFs to adopt electronic clinical surveillance technology to reduce and prevent healthcare associated infections;
• Develop standards and measures for data exchange and sharing across all care settings, including SNFs; and
• Implement a Value-Based Purchasing program methodology that will result in a 70 percent payback percentage each year.