(Aug. 31, 2026) - Today, the Kansas Hospital Association submitted comments to the Centers for Medicare & Medicaid Services on the proposed rule for the Calendar Year 2027 Outpatient Prospective Payment System. KHA expressed concern that the proposed net payment update of 2.4 percent is inadequate, given the continued financial pressures facing hospitals and health systems, including the proposed 0.8 percentage-point productivity adjustment.
KHA also raised concerns with several policies that could reduce access to hospital-based care, increase administrative burden and create additional financial pressure on providers. Among other recommendations:
- KHA urged CMS to withdraw the proposed site-neutral payment reduction for imaging without contrast furnished in excepted off-campus provider-based departments.
- Not finalize the proposed acceleration of the 340B remedy clawback or the proposed reduction in reimbursement for 340B-acquired drugs to ASP minus 33.4 percent.
- Return to a more deliberate process for removing procedures from the inpatient-only list.
- Withdraw the proposed expansion of prior authorization for additional botulinum toxin injection services.
- Reconsider the proposed expansion of the ambulatory surgical center covered procedures list because of patient safety concerns.
- Minimize the administrative burden associated with new separate NPI requirements for off-campus hospital departments.
Comments are due to CMS today, Aug. 31 and can be submitted using this link. Hospitals that have not yet submitted comments are encouraged to do so and may use KHA’s comments as a resource in developing their own submission. Member comments, including specific examples of how these proposals would affect patient access, hospital operations, finances or services in Kansas communities can be particularly valuable.