In September 2025, the Center responded to a proposed rule from the Centers for Medicare and Medicaid Services (CMS) regarding how the federal government pays for hospital services under the Medicare program. In our public comment on the Hospital Outpatient Prospective Payment System, the Center weighed in on hospital price transparency, site-neutral payment policy, and Medicare Advantage data transparency. 

Drawing on our work to equip employers and purchasers with pricing data and the challenges these efforts have uncovered, the Center expressed its support for the proposed enhancements to the hospital pricing data reporting requirements and the continued emphasis on compliance. Specifically, the Center recommended that CMS should: 

• Implement additional requirements for the data files to further standardize and improve their usability for price comparisons within and across markets. 

• Require hospitals to report the volume of services for which prices are reported, which is important to enable more accurate and refined analysis, oversight, and benefit design. 

• Finalize the proposal to align Medicare payments for drug administration services, regardless of whether the services are delivered in a physician’s office or a hospital outpatient department. We also recommended that CMS consider how this proposed policy’s impact may be limited by potential interactions with existing policies that provide hospitals with similar incentives to shift services to higher-paid settings and purchase physician’s offices, such as the 340B drug pricing program. 

• Move forward with requiring hospitals to report information on the prices they have negotiated with Medicare Advantage Organizations to improve Medicare Advantage price transparency.