Advisories
AHA Comments on CY 2027 Outpatient PPS and Ambulatory Surgical Center Payment Proposed Rule
August 28, 2026
The Honorable Mehmet Oz, M.D.
Administrator
Centers for Medicare & Medicaid Services
7500 Security Boulevard
Baltimore, MD 21244-1850
RE: CMS–1850–P, Medicare Program: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems; and Quality Reporting Programs; Including the Hospital Outpatient Quality Reporting Program and Ambulatory Surgical Center Quality Program; Request for Information on Strengthening the Standardization and Comparability of Hospital Price Transparency (HPT) Data; Prior Authorization; and Accrediting Organization (AO) Deeming for Emergency Medical Treatment and Labor Act (EMTALA), (Vol. 91, No. 128), July 7, 2026.
Dear Administrator Oz:
On behalf of our nearly 5,000 member hospitals, health systems and other healthcare organizations, our clinician partners — including more than 270,000 affiliated physicians, 2 million nurses and other caregivers — and the 43,000 healthcare leaders who belong to our professional membership groups, the American Hospital Association (AHA) appreciates the opportunity to comment on the Centers for Medicare & Medicaid Services’ (CMS’) hospital outpatient prospective payment system (PPS) and ambulatory surgical center (ASC) payment system proposed rule for calendar year (CY) 2027.
America’s hospitals and health systems, including their outpatient departments, are the backbone of the U.S. healthcare system, providing 24/7 care to patients and communities. Hospital care today is more advanced, more effective and more resource-intensive than ever, reflecting major gains in medical innovation and the highly skilled workforce, technology and infrastructure required to deliver it. Patients are living longer, recovering faster and receiving treatments that would have been unimaginable just a generation ago. As communities across the country face ever-increasing demand for healthcare services, it is essential that Medicare payment policies support the sustainability and availability of these providers and services.
Thus, we are concerned the proposed net payment update of 2.4% is not adequate given the unrelenting financial headwinds hospitals and health systems face. We are particularly concerned with the large proposed productivity cut of 0.8 percentage points, and urge CMS to work with Congress to reduce the magnitude of it for CY 2027 or eliminate the adjustment altogether. Moreover, we are concerned about other proposals that would negatively impact beneficiary access to hospital-level care and new technologies, while also greatly increasing regulatory burden. Specifically, we:
- Oppose CMS’ proposal to reduce payment for imaging without contrast services furnished by off-campus excepted provider-based departments (PBDs) and urge the agency to withdraw it.
- Recommend that CMS return to its standard process from 2025 for removing procedures from the inpatient-only (IPO) list.
- Recommend that CMS withdraw its proposed expansion of prior authorization to apply to additional botulinum toxin injection codes, which would affect services that are predominately medical, not cosmetic.
- Urge CMS to abandon the proposed expansion of the ASC covered procedures list (CPL) due to safety concerns arising from the inappropriately weakened standard and general exclusion criteria for the ASC CPL.
- Urge CMS to help mitigate the increased burden that the statutory requirement for hospitals to obtain separate National Provider Identifiers (NPIs) for each of their off-campus PBDs would place on hospitals, physicians, payers and Medicare beneficiaries.
We appreciate your consideration of these issues. Our detailed comments are attached. Please contact me if you have questions or feel free to have a member of your team contact Roslyne Schulman, AHA director for outpatient payment policy, at (202) 626-2273 or rschulman@aha.org.
Sincerely,
/s/
Ashley Thompson
Senior Vice President
American Hospital Association
Detailed Comments on the Outpatient Prospective Payment System Proposed Rule for CY 2027
Table of Contents
SITE-NEUTRAL REDUCTION IN PAYMENT FOR IMAGING WITHOUT CONTRAST SERVICES IN EXCEPTED OFF-CAMPUS PBDS
YEAR TWO OF ELIMINATING THE IPO LIST
EXPANSION OF BOTULINUM TOXIN INJECTION CODES FOR HOPD PRIOR AUTHORIZATION PROCESS
PAYMENT FOR SOFTWARE AS A MEDICAL SERVICE
Key Resources
Related Resources
AHA Center for Health Innovation Market Scan