Consumers First Submits Comments On OPPS CY 2026

Families USA, on behalf of Consumers First and joined by 16 organizations provided comments on the Medicare Hospital Outpatient Prospective Payment System (OPPS) proposed rule for calendar year 2026. Consumers First is a collective of members working together to hold the nation’s health care system accountable to providing everyone with affordable, high-quality, cost-effective care. One essential lever to achieving this goal is the enactment of improved Medicare payment policy, which in turn establishes a standard that is often adopted by commercial payers and Medicaid.

This letter provided recommendations across several key areas, including CMS proposals to:

• Allow hospitals to comply with the hospital price transparency rule by posting price estimates instead of dollars and cents negotiated rates, undermining the ability of people to know the price of health care before they receive services
• Extend site neutral payments to drug administration delivered by “grandfathered” off-campus provider-based departments, except for those hospitals classified as rural sole community hospitals, to ensure consumers pay the same price for the same service for physician administered drugs in more outpatient care settings.
• Repeal key health care quality measures from the hospital outpatient quality reporting program that would have held hospitals accountable for health equity and the social drivers of health, including the Hospital Commitment to Health Equity, The Screening for Social Drivers of Health, and The Screen Positive Rate for Social Drivers of Health measures.

Consumers First strongly supports CMS proposal to extend site neutral payments for drug administration to “grandfathered” off-campus provider-based departments, which represents a critical step to rein in key payment distortions that drive hospital consolidation and the delivery of unaffordable care for our nation’s families. At the same time, however, Consumers First opposes CMS proposal to allow hospitals to continue to post price estimates instead of their dollars and cents negotiated rates as well as roll back important requirements that would have held hospitals accountable to driving health equity improvements.