September 15, 2025- Last week, Vizient® submitted comments to the Centers for Medicare & Medicaid Services (CMS) on the CY 2026 Medicare Hospital Outpatient Prospective Payment System (OPPS) and Physician Fee Schedule (PFS) Proposed Rules. In Vizient’s OPPS comments, the company strongly opposed CMS’s proposals to expand site neutral payment policies, implement a new offset to address the 340B remedy, and conduct a burdensome drug acquisition cost survey.
“Site neutral cuts disregard the higher costs and patient complexity hospitals manage every day, undermining the resources hospitals rely on to provide 24/7 emergency services and high-acuity care,” said Shoshana Krilow, senior vice president of public policy and government relations for Vizient. “We urge CMS to reconsider these proposals, particularly given the financial pressures hospitals are already facing.”
Vizient further cautioned against CMS’s plan to impose a larger offset tied to the 340B remedy, noting it could reduce hospital reimbursement by more than $1 billion annually. Vizient also opposed CMS’s notice of intent to conduct a nationwide drug acquisition cost survey, citing the potential administrative burden, among other concerns.
In addition to the OPPS comments, Vizient responded to the CY 2026 PFS Proposed Rule, raising concerns about reimbursement inadequacy and the proposal to create a new mandatory Ambulatory Specialty Model (ASM). Despite a slight increase to the conversion factor, ongoing cuts and flawed payment methodologies would further strain providers, particularly those delivering care in facility settings.
As CMS updates these key payment policies, Vizient appreciates the opportunity to provide feedback and remains committed to advancing policies that ensure fair reimbursement, reduce unnecessary burdens, and protect patient access to high-quality care.
Learn more about Vizient’s advocacy and public policy efforts.