HFMA Comments on CY 2026 Hospital OPPS and ASC Proposed Rule

In a September 15, 2025, letter to CMS, HFMA submitted comments pertaining to CMS-1834-P CY 2026 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Proposed Rule. HFMA evaluates all payment proposals against its five principles of an effective payment system: quality, alignment of incentives, fairness and sustainability, simplification, and societal benefit. In the letter, HFMA expressed concerns with CMS’s proposals:

• Cutting payment for all drug administration services in excepted off-campus PBDs to the PFS-equivalent (40% of OPPS)
• Eliminating the Inpatient-Only (IPO) list over three years
• Altering ASC Covered Procedures List (CPL) criteria and general exclusions
• Accelerating the timeline for recoupment tied to the 2018–2022 340B underpayments
• Collecting market-based payment rate data to set IPPS relative weights for FY 2029
• Cutting reimbursement to FFRct and the 572x APC family
• Federal Price Transparency Strengthened Attestation Requirements
• Federal Price Transparency Changes to Payer-Specific Negotiated Charges Reporting Requirements
• Federal Price Transparency Replacement of Estimated Allowed Amounts