ASRT Responds to the Centers for Medicare and Medicaid Services Proposed Rules

The American Society of Radiologic Technologists filed two comments to the Centers for Medicare and Medicaid proposed rules Hospital Outpatient Prospective Payment System CMS1850-P or OPPS and The Medicare Physician Fee Schedule CMS-1848-P. In its comments, ASRT addressed concerns about the impact of these proposed rules on patient access to care.

The first proposed rule, OPPS, would revise the Medicare Hospital Outpatient Prospective Payment System and the Medicare Ambulatory Surgical Center payment system for calendar year 2027.

ASRT stated one concern is that the proposed policy could create patient access issues in communities where hospital outpatient departments serve as an essential source of imaging services, including rural and underserved areas and regions with limited freestanding imaging alternatives. See a full review of the areas of concern ASRT addressed in its letter to CMS.

In the second proposed rule, MPFS, which is the primary method of payment for enrolled heath care providers, ASRT addresses the high-cost disposable supplies, specific code valuation, request for information on duplicate laboratory testing, imaging and result sharing and interoperability, and changes to primary care and care management due to technology and clinical artificial intelligence. Read ASRT's detailed comments about MPFS in its letter to CMS.

CMS' proposed rules were issued in July 2026, and the public comment period closed on Aug. 31 and Sept. 14, respectively. After the release of the final rule this fall, the provisions are scheduled to take effect on Jan. 1, 2027. Questions about ASRT's comments may be sent to [email protected].