FFY 2026 IPPS Proposed Rule: Unleashing Prosperity through Deregulation of the Medicare Program
I. FY26 IPPS Proposed Rule Summary
II. ”Unleashing Prosperity through Deregulation of the Medicare Program”
III. National Medicare IPPS Estimates
IV. Provider Rates
On January 31, 2025 the White House released Executive Order 14192 to identify at least ten (10) existing regulations to be repealed. In the FFY 2026 IPPS Proposed Rule CMS issued a request for information (RFI) for Medicare stakeholders, including providers. Listed below are some notable areas whereby CMS is seeking input.
Streamline Regulatory Requirements
Existing regulatory requirements that could be waived, modified or streamlined
Medicare administrative processes (including quality and data reporting) creating significant burdens on providers that could be automated or simplified.
Opportunities to Reduce Administrative Burden of Reporting and Documentation
Medicare reporting and documentation requirements to simplify or reduce.
Redundant or overly complex reporting requirements. CMS also asks for input on cross-agency collaboration (Medicare and Medicaid).
Toyon’s Take
This RFI is a good opportunity for hospitals to convey burdensome and duplicative reporting to CMS. CMS cites Conditions of Participation (CoPs) and Conditions for Coverage (CFC), Quality, and value-based purchasing programs (VBP) as areas that are duplicative and that could be better streamlined. The American Hospital Association (AHA) released responded to the RFI with the top 100 ways that the administration could reduce the burden on hospitals and health systems. AHA’s comments discuss billing, payment, administrative requirements, quality and patient safety, telehealth, and workforce.
Additional examples of duplicative and burdensome Medicare cost reporting could include:
Excess information provided on Medicare cost report exhibits
For instance, to support Medicare Bad Debt, DSH, and Uncompensated Care (Exhibits 2A, 3A, 3B and 3C), CMS asks providers to report superfluous public health information (PHI) information, like patient name, sex and date of birth. The patient’s identification number is the only piece of information needed to reference a patient.
Furthermore, CMS’s instruction for uncompensated care (exhibits 3B and 3C) focuses on how a patient account is adjudicated to achieve a zero (0) balance. These instructions get into convoluted patient accounting of claims, when CMS’s concern should only be the accuracy of the amount of charity care and bad debt written-off over the course of a year.
Requiring providers to update financial assistance policies (FAPs) to recognize various forms of charity care and self-pay discounts is also cumbersome and there are no industry standards on how these updates are to be accomplished. At the same time, providers need to focus on ever changing state and federal compliance to update their FAPs accordingly.
Teaching providers are asked to reconcile when there are FTEs of interns and residents that cross-over (i.e., duplicative) with other teaching providers. In many cases the cross-over impact is immaterial. Also, most teaching hospitals are held to their 1996 FTE caps, and therefore there is no reimbursement impact from this burdensome exercise.