In the OPPS proposed rule comment letter, addressed to Centers for Medicare & Medicaid Services (CMS) Administrator Mehmet Oz, the organizations urged CMS to take additional steps to improve enforcement and compliance with the federal hospital price transparency rule.

Additionally, Consumers First recommended increasing the civil monetary penalty (CMP) for CMS noncompliance to $300 per bed per day for hospitals with 31 or more beds and removing the annual $2 million cap on the CMP for these hospitals. This, the organizations claimed, will send a stronger message.

Consumers First also encouraged CMS to require hospitals to display all negotiated rates in dollars and cents. “Only the negotiated rate, displayed in dollars and cents should be considered complete and accurate information for the purposes of the hospital price transparency rule.”

Furthermore, Consumers First recommended that CMS require hospitals to publish and pair quality information with pricing information. CMS should establish a process, the organizations advised, or build on existing processes, to engage a wide range of non-industry stakeholders to determine what kinds of quality information would be most appropriate and meaningful to pair with published prices.

Consumers First mentioned that it strongly supports CMS’s proposal to extend site-neutral payments to drug administration services delivered by “grandfathered” off-campus provider-based departments, starting in 2026. At the same time, Consumers First recommended that CMS go further and expand site-neutral payments to additional services and sites of care.

In the MPFS proposed rule comment letter, also addressed to Mehmet Oz, Consumers First expressed support for CMS’s proposal to cut the number of PE RVUs (Practice Expense Relative Value Units) for facility-based physician services. The organizations represented recommended that CMS take steps to ensure this proposed change does not negatively impact physicians who work in both the facility setting and a separate practice.

Furthermore, Consumers First recommended that CMS use a diverse set of data sources to determine physician payment rates, including hospital data (as used in OPPS), physician surveys, and routinely collected empirical data, to ensure that healthcare payments accurately reflect the value of primary care and the costs of providing a comprehensive version of it.

The letter writers recommended that CMS continue efforts to invest in primary care, streamline billing processes, and move away from the inefficiencies of traditional FFS (Fee For Service) by advancing more hybrid and population-based payment models.

Additionally, Consumers First expressed support for testing an alternative payment model at the individual physician level to assess cost and quality incentives that improve care for patients with heart failure and low back pain.

Consumers First strongly opposed proposals to remove the health equity adjustment, as retaining these quality measures is integral to ensuring quality performance, the organization explained.