AHA Comments on CMS FY 2027 Skilled Nursing Facility Proposed Payment Rule

June 1, 2026

The Honorable Mehmet Oz, M.D.
Administrator
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850

Re: Medicare Program; Prospective Payment System and Consolidated Billing for Skilled Nursing Facilities; Updates to the Quality Reporting Program for Federal Fiscal Year 2027; 91 Fed. Reg. 17,676 (April 7, 2026).

Dear Administrator Oz:

On behalf of our nearly 5,000 member hospitals, health systems and other healthcare organizations, including approximately 500 skilled-nursing facilities (SNFs), our clinician partners — more than 270,000 affiliated physicians, two million nurses and other caregivers — and the 43,000 healthcare leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS) fiscal year (FY) 2027 SNF prospective payment system (PPS) proposed rule.

SNFs play a critical role in the continuum of care. Ensuring access to this frequently used discharge destination is crucial for patients continuing their recovery following a hospitalization. Due to the important role of SNFs, we are concerned that the proposed FY 2027 payment update remains inadequate in light of sustained cost increases. As such, the AHA urges CMS to strengthen the FY 2027 SNF payment update by revisiting the market basket forecast and working with Congress to reduce the magnitude of the productivity adjustment. Further, we urge CMS not to pursue additional case-mix creep adjustments under the current request for information (RFI) framework, which risks duplicating prior parity adjustments and penalizing appropriate adaptation to the Patient-driven Payment Model (PDPM).

Our detailed comments follow.