CY 2027 Hospital Outpatient PPS Policy Changes and Payment Rates and Ambulatory Surgical Center Payment System Policy Changes and Payment Rates. CMS-1850-P Display

The commenter expresses concern that the proposal to treat all missing medical records as validation mismatches for eCQM validation will unfairly penalize hospitals for operational challenges beyond their control, such as retrieving records from external EMS agencies. They advocate for alternative approaches like grace periods or exception processes to avoid penalizing accurate reporting due to record unavailability.

Central Peninsula Hospital, a rural community hospital in Alaska, supports the proposed outpatient cost-of-living adjustment and the exemptions for rural Sole Community Hospitals regarding imaging reductions and 340B drug payments. However, the hospital opposes the accelerated pace of the 340B non-drug items and services offset, urging a slower, more gradual reduction.

The commenter, representing a Sole Community Hospital, opposes the proposed reduction in reimbursement for 340B-acquired drugs. They argue that the policy unfairly penalizes non-profit safety-net hospitals that provide 24/7 emergency care and serve low-income populations, while favoring Ambulatory Surgical Centers (ASCs) that have fewer operational mandates.

The commenter opposes the proposed cuts to ophthalmic procedure payments, arguing that these reductions threaten the economic viability of Ambulatory Surgical Centers (ASCs). They contend that these procedures are already underfunded and that further cuts will lead to staff shortages and higher costs for patients.

A retired attorney and Medicare beneficiary opposes the proposed "device-intensive" designation for CPT 0621T in the CY 2027 ASC payment rule. The commenter argues that the designation is unjustified because the procedure is implant-free, lacks FDA marketing authorization, and results in unfairly high coinsurance for patients compared to similar procedures.