Take Action · Public Comment Open
Amplify Your Voice for Patients
A Campaign for Physician-Led Hospitals
For the first time, Medicare is formally asking whether physician-led hospitals should be allowed to expand and compete. This is a once-in-a-generation opportunity — and it will only count if regulators hear from the physicians, medical societies and patient advocates who live this every day. Your comment is your voice. This toolkit makes it simple.
Comments are due June 9, 2026 — 11:59 p.m. EDT.
CMS opened a 60-day public comment window on the FY 2027 IPPS proposed rule. Comments must be received by 11:59 p.m. EDT on June 9 — once that window closes, it closes. Submit early, and encourage every colleague in your network to do the same.
Hear it from a physician leader: why this fight matters
Carlos J. Cardenas, MD, on how physician-led hospitals are transforming care — especially in communities that need it most. Watch it, then add your own voice before the deadline.
Carlos J. Cardenas, MDChairman of the Board & Chief Administrative Officer, DHR Health
Listen & Share
“April Ten Congress Pen”
An anthem for the moment by Dutch Rojas · play on Suno
Why your comment is critical
Regulators weigh the public record. When CMS reviews this rule, it counts who showed up — and a wave of thoughtful, first-hand comments from physicians and patients carries weight that lobbyists cannot manufacture.
Opponents of physician-led care are organized and well-funded. Silence is read as consent to the status quo. A few minutes of your time helps tip the balance toward competition and choice.
Why this is a win for patients
Physician-led hospitals consistently deliver lower prices, higher satisfaction and strong quality outcomes. Letting them expand means more options in communities where consolidation has quietly erased competition.
More competition is the proven, market-based way to bring down costs — without cutting access or care. Patients win when physicians can compete on quality and price.
What CMS is actually asking
Buried in the FY 2027 IPPS proposed rule is a Request for Information (RFI) — CMS is exploring whether to let physician-owned hospitals (POHs) voluntarily opt in to the Transforming Episode Accountability Model (TEAM), starting in regions not selected for mandatory participation. The agency is asking stakeholders to weigh in on questions such as:
• Should POHs be allowed a voluntary opt-in to participate in TEAM — and which hospitals should qualify?
• What waivers (for example, of the ACA Section 6001 expansion limits) are needed for POHs to succeed?
• What geographic and inclusion criteria should apply to opt-in hospitals?
• What program-integrity guardrails protect beneficiary choice and prevent patient steering?
• Which episode categories should be tested for POHs in TEAM?
• How should compliance be handled after TEAM and any temporary waivers end?
In plain terms: CMS is publicly recognizing physician-led hospitals as a tool to lower costs, improve outcomes and counter consolidation. Your comment helps answer these questions the right way.
Read the RFI in the official rule Federal Register · FY 2027 IPPS proposed rule — physician-owned hospital RFI begins at page 895First, what is the TEAM model?
The Transforming Episode Accountability Model (TEAM) is a new mandatory Medicare bundled-payment model that runs from January 1, 2026 through 2030. It holds hospitals financially accountable for both the cost and the quality of an entire episode of care — from surgery through the 30 days after discharge — for five common, high-volume procedures. Roughly 740 hospitals in selected geographic regions are required to take part.
Each hospital receives a single target price for the full 30-day episode, with payment adjusted up or down based on a quality score for patient safety and readmissions. The five surgical episodes are:
• Lower-extremity joint replacement (LEJR)
• Surgical hip & femur fracture treatment (SHFFT)
• Spinal fusion
• Coronary artery bypass graft (CABG)
• Major bowel procedure
CMS’s goal is to keep shifting Medicare away from fee-for-service toward value-based care — better coordination, lower spending and accountability for outcomes after the patient leaves. The RFI above asks whether physician-led hospitals should be allowed to opt in to this model — which is why this comment window matters.
Learn more about the TEAM model CMS Innovation Center · official model overviewOpen the official rule
Go to the FY 2027 IPPS proposed rule in the Federal Register and click the green “Submit a Public Comment” button.
Write your comment
Use the helpful hints below. Speak from your own experience, reference the RFI on physician-led hospitals in TEAM, and keep it specific to your community.
Sign it & submit by 11:59 p.m. EDT June 9
Include your name — don’t comment anonymously. A named comment carries far more weight. If you’re a physician, use the commenter category pull-down to identify yourself — choose “Health Care Professional/Association – Physician” (or simply “Physician”; radiologists have their own category). Then submit and save your confirmation.
Two things that make your comment count: sign it with your real name rather than submitting anonymously, and — if you’re a physician — choose “Health Care Professional/Association – Physician” (or simply “Physician”) from the commenter-category menu. The official Federal Register docket is the only place comments are counted.
Your story is your strongest argument
CMS reads thousands of comments. The ones that stand out are personal, specific and grounded in real community impact. Don’t just say you support the change — show why it matters where you practice.
Quantify the patients you serve. How many patients do you and your hospital care for each year? Concrete numbers make your community real to a regulator reading from Washington.
Describe your role in the community. What would be lost if your patients had fewer options? Speak to access, wait times, specialized services and the relationships you’ve built.
Explain what expansion would unlock. Be specific: new operating rooms, added beds, a service line you can’t currently grow because of the expansion ban. Tie it to patient benefit.
Connect to cost and competition. Note how more choice helps counter consolidation in your market and gives patients lower-cost, higher-quality alternatives.
Reference the RFI directly. Mention you’re responding to the TEAM model RFI on physician-led hospital participation in the FY 2027 IPPS proposed rule. It signals a focused, informed comment.
Keep it in your own words. Identical form letters carry less weight than authentic, individual voices. A few honest paragraphs beat a polished template every time.
Background thoughts to help your submission
You don’t have to make the argument from scratch. The record supporting physician-led hospitals is deep, bipartisan and growing. Cite any of these in your comment.
88 stakeholders — including one of the nation’s largest health insurers — called on Congress to deliver physician-led hospitals to meet community needs.
Read about the record coalition →Bipartisan legislation is in conference to let physicians open and operate hospitals in rural healthcare deserts.
See the bills and PHA advocacy →A 2023 study found physician-led hospitals could have generated up to $1.1 billion in Medicare savings in 2019 alone.
Physicians Advocacy Institute / Physicians Foundation, 2023 · view the studiesJohns Hopkins researchers found POHs charge 17.5% lower commercial negotiated prices and 46.7% lower cash prices than competing hospitals for the same procedures.
JAMA Network Open, 2023 · view the studyAnalysis of nearly 740,000 Medicare patients across 186 POHs found no evidence of cherry-picking — patient age, race, ethnicity and comorbidities were virtually identical to traditional hospitals.
Physicians Advocacy Institute, 2023 · view the studyMarkets with physician-led hospitals have 16.7% lower healthcare market concentration — a proven, market-based antidote to consolidation.
Review the research →