Sept. 19, 2025: Medicare Payment Reform Advocacy Update

| 3 Min Read

AMA provides input to CMS on outpatient hospital and ASC payment proposals

On Sept. 15, the AMA submitted a comment letter (PDF) in response to the Centers for Medicare & Medicaid Services (CMS) 2026 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System proposed rule. The AMA supported CMS’ continued use of the hospital market basket to update ASC payments, which reduces disparities and supports migration of services to lower-cost settings, and urged CMS to either eliminate the ASC scalar or integrate ASC and OPPS utilization into a single budget neutrality calculation.

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Regarding CMS’ proposal to reduce OPPS payments for drug administration services by 60% when furnished in excepted, off-campus hospital outpatient departments, the AMA reiterated policy supporting Medicare payment policies for outpatient services that are site neutral, provided they do not reduce overall Medicare payments. Reducing payments to hospitals will not guarantee the continued viability of physician practices that have faced more than two decades of stagnant Medicare payments. Rather than removing an estimated $280 million a year from Medicare spending for outpatient drug administration services, CMS should reinvest these savings in other Part B services, including payments under the Medicare physician fee schedule.

The AMA also supported CMS’ proposals to remove measures that were inappropriately adapted from inpatient programs and lack evidence of feasibility or value in outpatient, ASC or Rural Emergency Hospital settings. Finally, the AMA urged CMS to withdraw the proposed restrictions on accreditor criteria related to diversity, equity and inclusion. The Accreditation Council for Graduate Medical Education (ACGME) has successfully self-regulated graduate medical education for decades, ensuring patient safety and educational quality. Additional federal restrictions are unnecessary, risk undermining professional self-regulation and could create confusion. Next, CMS will review the AMA’s and other interested parties’ comments and is expected to issue a final rule on Nov. 1, 2025.

Report Medicare payment delays to AMA advocacy

The AMA is monitoring any potential delays in Medicare claims processing or other Medicare payment problems that could result from federal staffing reductions at CMS. Physicians and medical practice staff who experience Medicare payment delays or other obstacles that could be tied to reduced staffing levels at the agency or its Medicare Administrative Contractors (MACs) are asked to inform AMA advocacy staff of these problems by emailing [email protected] and including the subject heading “Medicare Payment Delay.” Staff will work to identify the reasons for reported delays and determine if they may be related to CMS staffing reductions. 

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