Association Comments on CY 2027 OPPS Proposed Rule

In an Aug. 31 letter to the Centers for Medicare & Medicaid Services (CMS), America's Essential Hospitals responded to the agency's Calendar Year (CY) 2027 proposed annual update to the Outpatient Prospective Payment System and Ambulatory Surgical Center payments. The association urged CMS to withdraw illegal and unjustified cuts to outpatient drug reimbursement for hospitals participating in the 340B Drug Discount Program, along with other policies that disproportionately harm essential hospitals.

Even after accounting for CMS' proposed increase in payments for non-drug items and services, this change would reduce total OPPS payments to essential hospitals by 5.7% and redistribute payments to hospitals that do not serve a safety net role in their communities. As a result, the policy will reduce access to care for low-income Medicare beneficiaries and increase Medicare cost sharing for all Medicare beneficiaries.

Specifically, the association urged CMS to:

• Withdraw proposed cuts to drug reimbursement for hospitals participating in the 340B Drug Pricing Program because of the flawed policy design and inadequate acquisition cost survey
• Establish an essential health system designation to better identify hospitals that serve a safety net role
• Rescind proposed acceleration of the 340B program remedy recoupment methodology
• Increase the proposed annual hospital payment update to match measured rates of inflation
• Cease expansion of cuts to off-campus hospital outpatient departments
• Reduce administrative burden associated with hospital price transparency obligations, provider attestation requirements, and domestic procurement tracking

Contact Director of Policy Rob Nelb, MPH, at [email protected] or 202.585.0127 with questions.