Call for Comments: Care Transformation Initiatives
Notice is hereby given that the public and interested parties are invited to submit written comments to the HSCRC on the following topic: Care Transformation Initiatives, as discussed at the April 15, 2026 Commission meeting.
Written comments on the questions outlined below should be submitted to
[email protected] no later than April 24, 2026.
HSCRC staff will also allocate time to discuss responses during the April 22, 2026 Total Cost of Care Workgroup meeting. Comments that have already been submitted do not need to be resubmitted.
Background
The Care Transformation Initiative (CTI) program was established in 2019, under an agreement with CMS, to encourage hospitals to innovate care of Medicare patients and drive total cost of care savings. The Commission’s expectation was for some hospital revenue to shift based on CTI performance, but with an expectation that these gains and losses would be reasonable.
In early 2024, the Commission voted to include a 2.5% stop loss provision to limit the risk to hospitals and volatility of Medicare revenue. However, additional losses could be spread across all hospitals losing revenue under CTIs in order to make the program revenue neutral. Based on historical performance, this additional loss was anticipated to be minimal. However, 2025 performance demonstrates significantly greater volatility than in previous years with a maximum effective stop loss of 5.36%--far more than the expected 2.5%.
As discussed at the April 15 meeting, the Commission is seeking comments on potential options for addressing these unanticipated and unintended results and for the FY2026 program.
CTI Stakeholder Comment Questions
- For FY25 results, please share comments on these potential options:
- No change.
- Setting stop loss at the hospital level to 2.5% or another specific level. To maintain the required revenue neutrality, funding would be reduced to the revenue-gaining hospitals.
- Changing the methodology for attributing savings to CTI programs. If commenting, please explain your suggested methodology changes.
- No payout at all for FY25.
- For the FY26 program, please share comments on these potential options:
- No change.
- Setting stop loss at the hospital level to 2.5% or another specific level. To maintain the required revenue neutrality, funding would be reduced to the revenue-gaining hospitals.
- Changing the methodology for attributing savings to CTI programs. If commenting, please explain your suggested methodology changes.
- No payout at all for FY26.
- Other suggested options
