CHA Submits Comments on Outpatient Prospective Payment System Proposed Rule

The Centers for Medicare and Medicaid Services (CMS), in its Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Proposed Rule for calendar year 2026, proposes a net 2.4% increase in payment rates.  The rule also includes “site-neutral” payment policies for drug administration services in grandfathered off-campus hospital outpatient departments (HOPDs), which would reduce Medicare reimbursement for these services; phasing out the inpatient-only (IPO) list that was designed to protect beneficiaries; expediting the 340B remedy timeline for repayment for non-drug services and conducting a new drug acquisition cost survey; and modifying the price transparency requirements for hospitals, among other provisions.

In a comment letter submitted to CMS on Monday, September 15, the Connecticut Hospital Association (CHA) stated that the 2.4% increase is inadequate and does not keep pace with the unique inflationary environment that is eroding hospitals’ financial health, particularly in the face of the proposal to claw back billions of dollars in 340B-related payments from hospitals at a far faster rate.  CHA also urged CMS to eliminate the productivity cut.

CHA strongly opposes CMS’s attempts to accelerate the timeline of recoupment of funds from hospitals under the 340B Final Remedy Rule.  Quadrupling the reduction factor from 0.5% to 2% per year and shortening the original timeframe from 16 to six years will not only destabilize hospital operations but will also threaten access to care, especially for vulnerable communities that rely heavily on 340B-covered institutions.

In the letter, CHA emphasized that hospital transparency requirements in the proposed rule, intended to comply with this year’s executive order, are overly burdensome and offer limited value to patients.  Connecticut hospitals and health systems are committed to providing patients with meaningful information that they can use to make informed decisions about their care, including out-of-pocket cost estimators for common services and procedures, but listing privately negotiated payer prices will confuse and frustrate patients.

Additionally, CHA continued to underscore the fundamental differences between hospitals and other sites of care, encouraging CMS to withdraw its proposal to expand site-neutral payment cuts to drug administration services furnished in off-campus provider-based departments (PBD).

Click here to read CHA’s full comment letter.