AAMC Comments on CY 2025 OPPS Proposed Rule

The AAMC submitted Sept. 9 comments (PDF)in response to the Centers for Medicare & Medicaid Services (CMS) Calendar Year (CY) 2025 Outpatient Prospective Payment System (OPPS) proposed rule [refer to Washington Highlights, July 12].

Among the comments provided to the agency, the AAMC asked for an increase to the market basket update to account for increased labor and supply costs. The association asked the CMS to improve reimbursement for cell and gene therapies by excluding them from packaging policies and by reimbursing separately for the full range of services provided in connection with cell therapies such as CAR-T cell therapy. The association also urged CMS not to finalize proposed Medicare Conditions of Participation requirements for obstetrical services to improve maternal health outcomes. Other comments on the rule's payment proposals touched on an array of topics including the outlier threshold, remote services, separate payment for diagnostic radiopharmaceuticals, policies related to Medicaid, prior authorization, and drug pricing among other proposals.

Regarding hospital quality programs, the AAMC requested the agency to delay mandatory reporting of core clinical data elements and linking variables for the hybrid electronic health records-based measures and provide additional technical support to hospitals voluntarily reporting these measures. Additionally, the association responded to a request for information, Emphasizing Patient Safety in the Overall Hospital Quality Star Ratings, and urged the agency to ensure any future policies that emphasize patient safety best reflect patient priorities and appropriately balance safety with important areas like patient experience and mortality.