The Society for Healthcare Epidemiology of America (SHEA) has submitted formal comments to the Centers for Medicare & Medicaid Services (CMS) regarding the Fiscal Year (FY) 2026 Medicare Hospital Inpatient Prospective Payment System (IPPS) and Long-Term Care Hospital Prospective Payment System (LTCH PPS) proposed rule. SHEA, a leading voice in healthcare epidemiology, infection prevention, and antimicrobial stewardship commends CMS for its continued commitment to quality improvement and offers targeted recommendations to strengthen evidence-based patient safety, health equity, and data-driven care.
Key Positions and Recommendations:
- Crosscutting Quality Programs
SHEA supports CMS’s proposal to remove the COVID-19 exclusion from quality measures beginning in FY 2027, recognizing the importance of consistent benchmarking. However, SHEA strongly urges CMS to retain Social Drivers of Health (SDOH) measures until robust alternatives are developed, citing their critical role in addressing health disparities.
- Hospital Readmissions Reduction Program (HRRP)
SHEA supports the inclusion of Medicare Advantage (MA) patients and the reduction of the performance period from three to two years. However, the society raises concerns about potential double penalties for hospitals due to MA plan denials.
- Hospital Value-Based Purchasing (VBP) Program
SHEA opposes the removal of the Health Equity Adjustment (HEA), emphasizing its importance in supporting hospitals that serve vulnerable populations. The organization supports updates to complication measures for hip and knee arthroplasty.
- Hospital-Acquired Conditions (HAC) Reduction Program
SHEA supports updating baseline data for benchmarking and recommends the inclusion of new NHSN measures such as hospital-onset bacteremia (HOB) and antibiotic-treated C. difficile infection (HT-CDI). Additional recommendations include improved risk adjustment for complex cases and refinement of CAUTI criteria to enhance specificity.
- Hospital Inpatient Quality Reporting (IQR) Program
SHEA supports retiring the COVID-19 vaccination measure for healthcare personnel and encourages CMS to explore new measures focused on nutrition, patient and staff well-being, and loneliness as a social determinant of health.
- Extraordinary Circumstance Exception (ECE) Policy
SHEA supports codifying and expanding ECE policies to allow for time extensions during public health emergencies and disasters.
- Medicare Promoting Interoperability Program
SHEA endorses the addition of a bonus measure for public health reporting using the Trusted Exchange Framework and Common Agreement (TEFCA).
- Performance-Based Measures and FHIR Integration
SHEA supports the use of Fast Healthcare Interoperability Resources (FHIR) to enhance data quality and reduce reporting burdens. The organization recommends prioritizing high-volume adverse events, engaging clinical experts, and providing technical support for implementation.
About SHEA
The Society for Healthcare Epidemiology of America (SHEA) works to advance the science and practice of healthcare epidemiology and infection prevention. Founded in 1980, SHEA promotes education, research, and advocacy to improve patient care and safety. For more information, visit www.shea-online.org.
Media Contact: Lindsay MacMurray, lmacmurray@shea-online.org
