About this episode
The Centers for Medicare and Medicaid Services has finalized the 2026 Outpatient Perspective Payment System (OPPS) rule, with most policies taking effect on January 1, 2026. Jenna Stern, Vice President of Regulatory Affairs and Public Policy at Vizient, joins host Carolyn Liptak, Pharmacy Executive Director in Vizient's Center for Pharmacy Practice Excellence, to discuss key updates to payment policies, payment rates, and quality provisions affecting Medicare beneficiaries receiving care in hospital outpatient departments and ambulatory surgical centers.
Guest speaker:
Jenna Stern
Vice President of Regulatory Affairs and Public Policy
Vizient
Host:?
Carolyn Liptak, MBA, RPh
Pharmacy Executive Director
Vizient
Verified Rx Host
Show Notes:
00:05 — Introduction
Announcer welcomes listeners to VerifiedRx.
Host Carolyn Liptak, Pharmacy Executive Director at Vizient, introduces the episode focus:
the 2026 CMS Outpatient Prospective Payment System (OPPS) Final Rule.
Guest: Jenna Stern, VP of Regulatory Affairs and Public Policy at Vizient.
01:12 — Overview of the OPPS Final Rule
OPPS sets Medicare payment for most hospital outpatient services.
Published annually (typically November), effective January 1.
Covers payment rates, policies, quality programs, and compliance requirements.
Note: CMS delayed enforcement of hospital price transparency requirements until April 1, 2026.
01:34 — Key Takeaways From the 2026 Final Rule
Jenna’s high-level insights:
Hospitals will continue facing financial pressure in 2026.
Modest payment rate increase combined with reimbursement-reducing policies.
Expansion of site-neutral payment policies will be particularly impactful.
Rule reflects emerging administration priorities shaping future policy.
02:21 — OPPS Payment Rate Update for 2026
CMS finalized a 2.6% OPPS schedule increase factor for hospitals meeting quality reporting requirements.
02:40 — What the 2.6% Increase means
Based on:
3% market basket update
–0.7% productivity adjustment
Results in a modest net increase.
Slightly better than the proposed 2.4% increase, though still viewed as inadequate.
CMS estimates $8 billion increase in total OPPS payments compared to 2025.
03:37 — 340B Remedy Offset: Background
From 2018–2022, CMS paid for 340B drugs at ASP –22.5%.
Prior Supreme Court decision from 2022 found that CMS lacked authority to vary rates as finalized in prior rulemaking (e.g., without using drug acquisition cost surveys to inform policy).
04:13 — 340B Remedy Offset in the 2026
