Last month, AACI submitted comments in response to Calendar Year 2027 Hospital Outpatient Prospective Payment System (OPPS) Policy Changes and Payment Rates and Ambulatory Surgical Center Payment System Policy Changes and Payment Rates (CMS-2026-2344), proposed by the Centers for Medicare & Medicaid Services (CMS).
Throughout its comments, AACI noted that the proposed rule does not keep pace with sustained increases in operating costs for cancer centers, including labor, pharmaceuticals, and supplies. The comments address concerns with three specific provisions that are relevant to AACI members:
Expanding site-neutral payments to apply a Physician Fee Schedule-equivalent rate to certain services without contrast furnished in excepted off-campus HOPDs
Reducing 340B reimbursement from Average Sales Price (ASP) + 6 percent to ASP − 33.4 percent, which would increase OPPS payments for non-drug items and services with a corresponding budget-neutral adjustment
New provider-based attestation, National Provider Identifier, and enrollment requirements, including updates to systems, billing, compliance, and workflows
The proposed rule aims to make health care more affordable for patients. However, provisions like those described above could have unintended consequences among underserved communities where access to quality care is limited. AACI shared the following recommendations to balance the goals of affordable care and patient access:
Expanding site-neutral payments
Recommendation: AACI requests that CMS acknowledge the unique role that hospitals and Hospital Outpatient Departments (HOPDs) play in their communities and adopt a payment approach that reflects the higher-acuity patients specialized infrastructure, and broader community responsibilities of HOPDs.
Reducing 340B reimbursement
Recommendation: AACI urges CMS to reconsider the proposed reimbursement reduction for 340B-acquired drugs and adopt a payment policy that preserves hospitals' ability to reinvest 340B savings into patient care, community services, and access to comprehensive cancer treatment.
New provider-based requirements
Recommendation: AACI encourages CMS to provide sufficient operational guidance and implementation time to minimize administrative burden and payment disruptions for cancer centers with multiple outpatient locations.
On August 25, The Senate 340B Bipartisan Working Group, composed of U.S. Senators Jerry Moran (R-KS), Tammy Baldwin (D-WI), Shelley Moore Capito (R-WV), Tim Kaine (D-VA), John Boozman (R-AK), and John Hickenlooper (D-CO), introduced the SUSTAIN 340B Act, which aims to improve stability, clarity, and transparency in the 340B program and offers a more measured approach to 340B reform than the CMS proposed rule.
Last month, we launched the AACI Public Policy Roundup newsletter to provide a seasonal snapshot of AACI's ongoing public policy and advocacy activities. This quarterly publication will take the place of AACI Commentary in August, November, February, and May, to provide a more focused look at the policy issues shaping the oncology field.
Read the Summer 2026 issue.
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The 2026 Government Relations (GR) Forum is scheduled for 2:00 pm central time on Monday, October 26. The GR Forum will be held in conjunction with the 2026 AACI/CCAF Annual Meeting, October 25-27, at the Chicago Marriott Downtown Magnificent Mile. The GR Forum is not CME accredited and pre-registration is required.
AACI’s annual joint Hill Day with the American Association for Cancer Research will take place Thursday, May 20, 2027, in Washington, DC. Registration will open in early 2027.