AHA Statement on CY 2026 OPPS Proposed Rule

Ashley Thompson
Senior Vice President, Public Policy Analysis and Development
American Hospital Association

July 15, 2025

The AHA is disappointed that CMS proposes an inadequate Medicare outpatient hospital payment update as many hospitals — especially those in rural and underserved communities — operate under challenging financial pressures.

We oppose the proposal to expand “site-neutral” cuts and eliminate the inpatient-only list, as both policies fail to account for the real and crucial differences between hospital outpatient departments and other sites of care. Studies show hospital outpatient departments are more likely to serve Medicare patients who are sicker, more clinically complex, and more likely to be disabled or living in poorer, rural communities than patients treated in independent physician offices.

We are also concerned with CMS’ proposal to claw back billions of dollars from hospitals at a far faster rate than originally promised. It is important to remember that this clawback punishes 340B hospitals for the agency’s own mistake in implementing a policy that a unanimous Supreme Court held to be unlawful. Doubling down on that unlawfulness, the proposed recoupment is both illegal and unwise, and it should not be finalized.

Finally, we are concerned about the proposal to pursue a burdensome acquisition cost survey, especially if the agency’s goal is to drastically reduce Medicare payments to hospitals that serve the nation’s most vulnerable communities.

We look forward to reviewing these proposals in more detail and participating in the comment process with the agency.

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