HFMA Comments on CY 2027 Hospital OPPS and ASC Proposed Rule

In an August 31, 2026, letter to CMS, HFMA submitted comments pertaining to the CY 2027 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center proposed rule. HFMA evaluates payment policy against five principles of an effective payment system: quality, alignment of incentives, fairness and sustainability, simplification, and societal benefit.

HFMA supports CMS’s goals of improving payment accuracy, advancing beneficiary access, encouraging appropriate sites of care, and reducing unnecessary healthcare spending. At the same time, several proposals in this rule, particularly when considered together, could create significant financial and operational disruption without sufficient evidence that the resulting savings will translate into better value for Medicare beneficiaries.

We therefore encourage CMS to evaluate not only the individual merits of each proposal, but also their cumulative effect on access, affordability, administrative burden, innovation, and the financial capacity of providers to serve their communities.

Specifically, HFMA is concerned with CMS’s proposals for:

• Overall, Payment Adequacy Under the OPPS
• 340B Drug Payment Policy
• 340b Recoupment Methodology and Payment Reduction
• Ensure Site-Neutral Payment Reflects Comparable Patients, Services and Costs
• Support Innovation While Improving New Technology Payment Policies
• Refine a Deliberate Approach to Eliminating the Inpatient-Only (IPO) List
• Support Hospital Price Transparency Standardization While Reducing Administrative Burden
• Reduce Low-Value Quality Reporting
• Ensure Prior Authorization Reduces Waste Without Delaying Care