The AAMC submitted comments in response to the Centers for Medicare & Medicaid Services (CMS) Calendar Year (CY) 2026 Outpatient Prospective Payment System (OPPS) proposed rule [refer to Washington Highlights, July 18].
The AAMC’s comments focused on the financial impact and negative consequences of many of CMS’ proposals (PDF) and asked for an increase to the proposed 2.4% payment update to reflect higher growth in labor and supply costs amid financial uncertainty. The AAMC urged the agency to not accelerate the existing 16-year claw back timeline of nondrug items and services as part of its remedy for Part B drug payment reductions to 340B hospitals. The association also opposed the CMS’ proposal to extend “site-neutral” policies to drug administration services in excepted off-campus provider-based departments, as these payment cuts are likely to reduce access to care, particularly for the sickest and most complex patients.
Comments further expressed significant concerns with the expansion of “site-neutral” payment policies to on-campus clinic visits or for other services provided at on- or off-campus Hospital Outpatient Departments as these significant cuts in payment would reduce access to care. The AAMC also urged the CMS to withdraw its survey of OPPS drug acquisition costs due to the significant burden associated with collecting data that quickly becomes outdated from frequent acquisition cost changes and should not base Part B drug reimbursement rates on the results of any future survey. Lastly, the AAMC requested that the agency not eliminate the inpatient only list and instead encouraged the CMS to continue to solicit stakeholder feedback to comprehensively evaluate on an annual basis which procedures should remain in the inpatient setting, balancing concerns about beneficiary safety and outcomes and evolving standards of care.
Specific to graduate medical education, the AAMC asked the agency not to finalize the proposed changes to the definition of approved medical residency program. Related to quality in the Outpatient Quality Reporting Program, the comments encouraged the CMS to adopt proposed measures with modifications, finalize measure modifications and removals as proposed, and align Extraordinary Circumstances Exception policies with those policies adopted for CMS inpatient hospital quality reporting and performance programs.