The Centers for Medicare and Medicaid Services (CMS) issued the 2027 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System proposed rule on July 2, proposing a 2.4% increase to OPPS payment rates that reflects a market basket update of 3.2% reduced by a productivity adjustment of 0.8%.

The proposed rule continues to move services off the inpatient-only (IPO) list and add services to the ASC covered procedure list (CPL), adjusts ambulatory payment classification (APC) groupings, updates the ASC and OPPS quality reporting programs, and adds a provision to pay off-campus imaging services at the Physician Fee Schedule (PFS) rate, among other proposals.

Provisions of note to the field of cardiology include:

• IPO Changes: CMS proposes to remove approximately half of the remaining IPO services. Due to their clinical complexity, the agency plans to remove the cardiovascular family of services from the IPO list in 2028.
• Imaging Without Contrast: The agency proposes applying the PFS equivalent payment rate for any HCPCS codes assigned to the imaging without contrast APCs when provided at an off-campus provider-based department. Rural Sole Community Hospitals would be exempt from this policy.
• 340B Payment Policy: Noting studies showing vast disparities between drugs acquired through the 340B program and those outside the program, CMS has introduced policy to more accurately align Medicare payments with hospital drug acquisition costs. Specifically, the agency proposes to pay for 340B acquired drugs at the drug's Average Sales Price (ASP) minus 33.4% for 2027.
• CPL Changes: The agency proposes adding 618 procedures to the ASC CPL.
• APC Changes: CMS proposes initial or revised APC assignments for several cardiovascular services including Cardiac PET/CT, C-Codes describing PCI With Drug-Eluting Stents, Cardiac Contractility Modulation Systems, Endovenous Femoral-Popliteal Arterial Revascularization with Placement of Stent Graft, and WiSE® (Wireless Stimulation of the Endocardium Technology) CRT System.
• Software-Based Medical Services: CMS proposes a new interim payment methodology for software-based medical services with algorithmic analyses (formerly known as software as a service [SaaS]), which will temporarily place these services in New Technology APCs.
• ASC and OPPS Quality Reporting Programs:
  • Hospital outpatient departments and ASCs that fail to report required quality data will receive a 2% payment reduction to their annual payment update.
  • CMS expands the OPPS data validation program to include electronic quality measures, requiring hospitals to demonstrate that reported quality measure data accurately match the medical record.
  • The agency is seeking additional information on potential stratification of the All-Cause Transfer/Admission measure.

For more on the OPPS proposed rule, access the full text and accompanying Press Release and Fact Sheet. ACC Advocacy staff will continue to review the proposals, keep members informed of key developments and submit formal comments by Aug. 31.

Stay tuned to the ACC Advocate newsletter and ACC.org/Advocacy for the latest updates.

Clinical Topics: Cardiovascular Care Team

Keywords: ACC Advocacy, Centers for Medicare and Medicaid Services, U.S., Outpatients, Hospitals, Policy