Premier Submits Comments on CY 2026 Medicare Outpatient and Physician Fee Schedule Proposed Rules

*:last-child]:mb-0 [&>*:last-child]:pb-0 [&>p]:font-normal text-left [&>.prm-button-bar]:justify-start [&_.portable-text-link]:font-semibold [&_.portable-text-link]:underline [&_.prm-button-bar_a]:no-underline [&_li]:text-light-gray [&_p]:text-light-gray">

Premier submitted comments on the calendar year (CY) 2026 Medicare Physician Fee Schedule (PFS)/Medicare Shared Savings Program (MSSP) and the Outpatient Prospective Payment System (OPPS) proposed rules.

PFS/MSSP

In its comment letter responding to the PFS/MSSP proposed rule, Premier urged the Centers for Medicare & Medicaid Services (CMS) to focus on refining MSSP policies, enhancing the Ambulatory Specialty Model (ASM), and improving alternative payment models (APMs) to better support providers in the movement to value-based care. In addition, Premier called for policies to ensure sustainable financing for innovative health technologies.

Specifically, Premier urged CMS to consider the following recommendations:

• Practice expense component of the PFS: Conduct additional data analysis before changing the practice expense methodology, which could have an outsized impact on hospital-based providers in rural areas.
• Financing for digital health technologies: Explore the use of data collected from performance-based contracting arrangements as a pathway to inform CMS coverage and/or reimbursement decisions for novel digital health technologies and SaaS solutions.
• "Bona fide service fee": Abandon CMS' proposal to alter the definition of "bona fide service fee."
• Skin substitutes: Finalize CMS' skin substitute policy and remove related payments from the Medicare Shared Savings Program (MSSP) financial calculations for 2025 and earlier.
• ASM: Modify its quality measurement methodology to remove topped out measures and reward improvement, detail financial reconciliation and patient attribution methodologies for overlapping payment models, and exclude performance-based increases from the financial reconciliation of overlapping models such as MSSP.
• MSSP:
  • Delay downside risk acceleration in MSSP by two years.
  • Address challenges in Medicare clinical quality measure reporting by expanding claims data or limiting reporting to attributed beneficiaries.
  • Enhance specialty integration through testing of specialty attribution, unique benchmarks for sub-populations, and concurrent risk adjustment.
  • Develop a rural-specific MSSP track.
  • Provide a higher risk track option within MSSP.
• Incentives for participating in APMs: Address erosion of APM participation incentives by offering APMs with low nominal risk for providers unable to assume high levels of downside risk, exclude enhanced Medicare Part B payments from benchmarks and reconciliation, and streamline APM reporting.

OPPS

Among other recommendations provided in its comment letter on the OPPS proposed rule, Premier urged CMS to make the following revisions to its proposals:

Payment update: Enhance the proposed payment update of 2.6 percent as it is woefully insufficient to cover the impact of labor expenses, inflation and other exogenous influences.

340B drug remedy update: Abandon proposed changes to the 340B remedy because it is inconsistent with the Medicare statute and longstanding CMS precedents.

Financing for digital health technologies: Explore the use of data collected from performance-based contracting arrangements as a pathway to inform CMS coverage and/or reimbursement decisions for novel digital health technologies and SaaS solutions.

Drug Acquisition Cost Survey: Minimize the burden on providers to complete the drug acquisition cost survey.

Drug administration site-neutral policy: Abandon the site-neutral policy proposal for drug administration on previously exempted off-campus provider-based departments because the costs of safely storing and delivering drugs in an outpatient hospital site are higher than at physician practices and CMS provides no clinical basis that the increase in drug administration in outpatient hospital sites is unnecessary.

Removal of Inpatient Procedure Only (IPO) list: Empower clinicians, using their clinical judgement in certain situations, to override the inpatient only requirement and receive payment for procedures performed in the outpatient setting.

Hospital price transparency: Delay further revisions of the Hospital Price Transparency (HTP) requirements and, instead, focus on enforcing Transparency in Coverage requirements to empower patients with more personalized, actionable pricing data than current HPT reporting requirements afford; and

Market-based MS-DRG rates: Abandon pursuing a market-based MS-DRG payment rate setting methodology, but rather look to lessons-learned from the Maryland All Payer Model for a multi-payer approach.