Premier Submits Comments on CY 2025 Outpatient Proposed Rule

Premier submitted comments on the CY 2025 Outpatient Prospective Payment System (OPPS) proposed rule. In our detailed comments, Premier urged CMS to:

• Adopt new or supplemental data sources to ensure labor costs are adequately reflected in the Medicare hospital payment update;
• Finalize its proposal to pay separately for diagnostic radiopharmaceuticals above the $630 threshold;
• Work with stakeholders to evaluate whether $10 is an adequate level of reimbursement to offset increased costs of sourcing domestically produced non-highly enriched uranium;
• Expand the inpatient and outpatient payment adjustments for domestically sourced PPE to include additional PPE, including non-surgical N95 masks and isolation gowns;
• Abandon its proposal to establish a new obstetrics services condition of participation for hospitals and critical access hospitals;
• Work with stakeholders to finetune its portfolio of health-equity related measures, including continuing to test its screening for social drivers of health measures prior to requiring reporting or adopting into additional programs; and
• Delay mandatory reporting of the two hybrid measures in the Hospital Inpatient Quality Reporting (IQR) Program for at least two years.