Summarizing public comments on federal rules
Medicare Hospital Outpatient and Ambulatory Surgical Center Payment Updates for 2026
This page summarizes public comments on a proposed federal rule using using AI-assisted analysis and quote extraction. Below is a brief overview of the rule and timeline.
What this rule proposes: The Centers for Medicare & Medicaid Services (CMS) is proposing updates to the Medicare Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) payment system for calendar year 2026. The rule would revise payment formulas, adjust quality reporting requirements, and strengthen hospital price transparency enforcement. It also seeks public input on future quality measures related to well-being and nutrition, and explores refinements to how services are paid when performed in outpatient clinics or physician offices.
Official title: Medicare and Medicaid Programs: Hospital Outpatient Prospective Payment and Ambulatory Surgical Center Payment Systems; Quality Reporting Programs; Overall Hospital Quality Star Ratings; and Hospital Price Transparency
Agency: Centers for Medicare & Medicaid Services
Comment Deadline: September 15, 2025
Published: July 17, 2025
Docket ID: CMS-2025-0306
Comment Themes
- patient safety
- cost effectiveness
- reimbursement policy
- transparency issues
Public Sentiment
🟢 20% Support
🔴 80% Oppose
Based on analysis of approximately 108 public comments.
Sentiment estimates are based on large language model classification (currently GPT-4o), which includes both direct statements and inferred positions. Deduplication helps surface original voices and recurring themes. Our methods are still evolving.
Last updated: 2025-07-26
Requesting an update helps prioritize this rule.Public Comment Summary
This summary reflects the most common points raised in public comments submitted on this rule.
Out of 108 submitted comments, 31 were unique after deduplication. Among the 15 comments that expressed a clear stance, 80% opposed the proposed CMS rule and 20% supported it. Opponents focused on the proposed uniform reimbursement cap for skin substitutes, calling it arbitrary and warning that it could reduce access to effective treatments, particularly for vulnerable populations. They also raised concerns about the removal of the inpatient-only list, citing patient safety risks in ambulatory surgical centers and negative financial impacts on teaching hospitals. Supporters, though fewer in number, welcomed the 2.4% increase in payment rates, the expansion of the ASC Covered Procedures List, and the removal of the inpatient-only list, arguing these changes could improve patient access and reduce costs. Many comments did not take a clear stance but instead provided technical feedback, policy clarifications, or concerns about specific aspects of implementation, including the two-midnight rule, site-of-care decisions, and transparency requirements.
Comment Processing Summary
Out of 108 total comments, we applied multi-level deduplication to reduce repetition and highlight original, personally written submissions. This helps capture a more representative range of public input.
- 31 remained after removing exact duplicates
- 31 after filtering near-duplicates (name swaps, minor changes)
- 31 were considered clearly original (~28.7%)
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Representative Quotes
Showing 0 out of 27 sampled from original, non-duplicate comments.
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