ACAP Comment Letter on the CY 2025 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment System Proposed Rule

On September 6, ACAP submitted its comment letter to CMS on the Calendar Year (CY) 2025 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Payment System Proposed Rule (HHS-0938-AV35).

Key themes of the comment letter include:

  • ACAP’s strong support of the proposed changes to implement nationwide 12-month continuous eligibility for children, as passed by Congress in 2022.  
  • ACAP’s strong support of the three proposed additional exceptions to the Medicaid clinic services benefit four walls requirement for services provided outside of Indian Health Services (IHS)/Tribal clinics, behavioral health clinics, and clinics in rural areas. 
  • ACAP’s support of CMS’s two proposed changes aimed at improving Medicare enrollment and increasing access to care for people who were formerly incarcerated.

Read the comments in detail, with additional background, via the link to the right.