On July 13, 2017, CMS issued the Calendar Year (CY) 2018 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Payment System (ASCPS) proposed rule (Proposed Rule). CMS proposes to update OPPS rates by 1.75 percent for CY 2018 and to increase payment rates under the ASCPS by 1.9 percent. Additionally, as detailed below, CMS proposes several potential policy changes, including significant reductions to Medicare payments for drugs that are acquired under the 340B Drug Pricing Program.

CMS is accepting comments on the Proposed Rule until September 11, 2017 and indicated it anticipates issuing a final rule on or about November 1, 2017. King & Spalding’s Healthcare and FDA & Life Sciences Practice Groups welcome the opportunity to assist providers, product manufacturers, and other interested parties with analyzing the provisions of the Proposed Rule, submitting comments and preparing for compliance with anticipated changes to OPPS and ASC reimbursement policy.