ACR Addresses Site-Neutral Payment in HOPPS Comments

ACR^® submitted comments to CMS regarding the calendar year (CY) 2027 Hospital Outpatient Prospective Payment System (HOPPS) proposed rule this week, providing feedback on several payment and policy proposals affecting radiology and radiation oncology.

A primary focus of ACR's comments was CMS' site-neutral proposal to apply Physician Fee Schedule (PFS)-equivalent payment rates to imaging services assigned to imaging without contrast Ambulatory Payment Classifications (APCs) furnished in certain off-campus hospital outpatient departments. ACR cautioned against the proposal and urged CMS to exclude preventive imaging services from the policy, establish a payment floor to prevent excessive reimbursement reductions and modernize the Appropriate Use Criteria (AUC) program with clinical decision support as a more targeted approach to reducing unnecessary imaging utilization.

The College also provided recommendations related to APC assignments, Software as a Medical Service (SaMS), diagnostic radiopharmaceutical payment, the 340B remedy offset and Hospital Outpatient Quality Reporting Program updates.

ACR looks forward to continued collaboration with CMS as the agency finalizes policies for CY 2027 in the HOPPS Final Rule this fall. For more information or if you have questions, contact Kimberly Greck, ACR Senior Economic Policy Analyst.