Public Comments
When relevant legislation, regulations, guidance, and other opportunities to shape policy related to health services research arise, UnityPoint Health may decide it is appropriate to develop an official position. The UnityPoint Health Government & External Affairs department serves as the primary liaison for regulatory submissions in response to state and federal rule-making and public requests for information, as well as communications advocating changes in state and federal policy direction or strategic initiatives.
Federal Comments
FY 2027 Hospital Inpatient Prospective Payment Systems Proposed Rule
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: June 8, 2026
This annual proposed rule offers Hospital Inpatient Prospective Payment Systems for acute care hospitals (IPPS) and the long-term care hospital prospective payment system and policy changes and Fiscal Year (FY) 2027 rates; requirements for quality programs; and other policy changes.
- UnityPoint Health Comment Letter
- FY 2027 Hospital Inpatient Prospective Payment System Proposed Rule
FY 2027 Inpatient Psychiatric Facilities Prospective Payment Systems Proposed Rule
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: June 1, 2026
This annual proposed rule offers a FY 2027 Inpatient Psychiatric Facilities Prospective Payment System rate updates and quality reporting revisions.
- UnityPoint Health Comment Letter
- FY 2027 Inpatient Psychiatric Prospective Payment Systems Proposed Rule
FY 2027 Hospice Wage Index and Payment Rate Update
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: June 1, 2026
This annual proposed rule offers FY 2027 Hospice Wage Index and payment rate updates and revises Hospice Quality Reporting Program requirements.
340B Rebate Model Pilot Program RFI
Agency: Health Resources and Services Administration (HRSA)
Date Submitted: April 20, 2026
This Request for Information (RFI) seeks stakeholder input related to a potential 340B Rebate Model Pilot Program.
Organ Procurement Organizations Conditions for Coverage
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: March 31, 2026
This proposed rule revises the Conditions for Coverage for Organ Procurement Organizations (OPOs) to clarify outstanding procedural questions and enable OPOs to make better informed decisions to achieve high performance resulting in the successful procurement, distribution, and transplantation of more life-saving organs.
Increasing Organ Transplant Access (IOTA) Model
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: February 9, 2026
This proposed rule offers revisions to the six-year mandatory Medicare payment model that aims to test whether performance-based incentive payments paid to or owed by participating kidney transplant hospitals increase access to kidney transplants for patients with end-stage renal disease while preserving or enhancing the quality of care and reducing Medicare expenditures.
- UnityPoint Health Comment Letter
- Alternative Payment Model Updates and the Increasing Organ Transplant Access (IOTA) Model Proposed Rule
CY 2027 Policy and Technical Changes to the Medicare Advantage Program
Agency: Centers for Medicare & Medicaid Services (CMS)
Date Submitted: January 26, 2026
This annual proposed rule offers Contract Year 2027 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, and Medicare Cost Plan Program.
State Comments
No 2026 comment letters
Legislative Positions and Collaborative Sign-On Letters
Nursing and Allied Health Education
Leading Organization: National Coalition of Hospital-based Schools of Nursing and Allied Health
Audience: Centers for Medicare and Medicaid Services (CMS)
Allen College joined 40 other hospital-based nursing schools in a Sign-On Letter dated June 8 urging CMS to alter its proposed negative changes to Federal NAH programs within the FY27 Inpatient Prospective Payment Systems proposed rule. In addition, the Coalition has worked with Congress and has pending legislation, Rebuild America’s Health Care Schools Act of 2025 (S. 1087 / H.R. 1708), to address most the proposed CMS changes.
Rural Community Hospital Demonstration Reauthorization
Leading Organization: Senator Chick Grassley
Audience: Public
Senator Chuck Grassley (IA) introduced the bipartisan Rural Community Hospital Demonstration Reauthorization Act (S. 4460) with 15 cosponsors. This legislation would extend the Rural Community Hospital Demonstration for five years and provides a lifeline to rural hospitals by allowing them to test innovative hospital payment models under Medicare that boost financial sustainability to maintain and improve healthcare access in rural communities. This specifically impacts UnityPoint Health hospitals in Fort Dodge and Grinnell. UnityPoint Health supports this legislation and are impacted hospitals are quoted in the Senator Grassley’s Senate introduction press release and Senate passage press release.
On May 5, Senator Grassley toured Grinnell Regional Medical Center. UnityPoint Health Chief Government Affairs and Philanthropy Officer, David Stark, offered some highlights for Senator Grassley of the impact that Rural Community Hospital Demonstration has had in Grinnell – here and here.
Leading Organization: Congressman Randy Feenstra
Audience: Public
Congressman Randy Feenstra (IA-04) introduced the bipartisan companion reauthorization bill (H.R. 8967) with 16 cosponsors, including Representatives Mariannette Miller-Meeks (IA-01), Ashley Hinson (IA-02), and Zach Nunn (IA-03). UnityPoint Health-Fort Dodge is within IA-04 and is quoted in Congressman Feenstra’s press release.
Compact Licensure Flexibilities
Leading Organization: Interstate Healthcare Collaborative
Audience: Senate and House Judiciary Committees
UnityPoint Health participated in a Sign-On Letter urging congressional leaders to support the States Handling Access to Reciprocity for Employment (SHARE) Act (S. 1101 / H.R. 2332). This legislation is aimed to help address workforce shortages by improving licensure compact implementation. Specifically, the SHARE Act requires the Federal Bureau of Investigation (FBI) to make available criminal history record information to a state occupational or professional licensing authority for background checks of individuals seeking a license under an interstate compact.
Medical Supply Chain Resiliency Act
Leading Organization: Premier, Inc.
Audience: House Ways and Means Committee
UnityPoint Health participated in a Sign-On Letter urging Rep. Jason Smith (R-MO), Chairman of the House Ways and Means Committee, asking that the Committee advance the Medical Supply Chain Resiliency Act – MSCRA (H.R. 2213). This bipartisan legislation provides the United States Trade Representative authority to negotiate medical supply chain security agreements that would secure fair treatment abroad for American medical devices, pharmaceuticals, and other vital healthcare supplies while ensuring that our nation’s healthcare providers have access to the essential medical supplies needed for high-quality patient care.
Department of Education Definition of “Professional Student”
Leading Organization: The Academy Advisors
Audience: U.S. Department of Education
UnityPoint Health joined other integrated health systems in a Stakeholder Letter related to the Department of Education Reimagining and Improving Student Education (RISE) Proposed Rule. The RISE rule implements the federal student loan-related provisions within HR1 (OBBBA). Among the provisions beginning in July 2026, OB3 provides that new graduate students will be limited to $20,500 in annual loans with a $100,000 lifetime maximum, while professional students will face a $50,000 annual limit and $200,000 aggregate cap. Both of these categories relate to advanced degrees beyond a bachelors.
Modernize Accountable Care to Accelerate Care Transformation
Leading Organization: National Association of Accountable Care Organization (NACCOS)
Audience: Centers for Medicare & Medicaid Services (CMS)
UnityPoint Accountable Care was among 128 Accountable Care Organizations in co-signing a Stakeholder Letter dated March 10, 2026, to thank CMS for its continued commitment to value-based care and recommend further steps to accelerate care transformation. Recommendations included embracing further innovation, accelerating transformation, protecting ACOs from fraud, waste and abuse, fixing inaccurate trend adjustments, and addressing the benchmark ratchet.
Accelerating Kids’ Access to Care Act
Leading Organization: Senator Chuck Grassley
Audience: Public
In 2025, Senators Grassley (IA) and Bennet (CO) re-introduced the bipartisan Accelerating Kids’ Access to Care Act to improve access to life-saving care for children with complex medical conditions. The legislation simplifies out-of-state Medicaid screening and enrollment processes for pediatric care providers, while retaining key safeguards to preserve the integrity of the program. This legislation was included in a Fiscal Year (FY) 2026 funding package. UnityPoint Health supported this legislation and was quoted in the Grassley press release celebrating its passage.
Medicare Telehealth Provider Flexibilities
Leading Organization: Alliance for Connected Care
Audience: Centers for Medicare & Medicaid Services (CMS)
UnityPoint Health joined 150+ organizations in signing a Stakeholder Letter dated January 20, 2026, thanking CMS for permanently allowing Medicare-enrollment practitioners to report and bill using their enrolled physical practice location and working with stakeholders to develop an alternate method of determining location for the purposes of payment that does not require the reporting of a home address and alignment across agencies.
For Further Information:
Please email Cathy Simmons, Executive Director, Government & External Affairs.
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Government & External Affairs
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