ASE Submits Comments on the CY 2027 Hospital Outpatient Prospective Payment System Proposed Rule

On August 26, ASE submitted comments to CMS Administrator Mehmet Oz on the CY 2027 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Payment System proposed rule. The letter’s central concern is a proposal to extend the volume-control methodology to imaging-without-contrast services in excepted off-campus provider-based departments, which would cut payment by roughly 60% for comprehensive transthoracic echocardiography (CPT 93306) by paying it at the Physician Fee Schedule-equivalent rate. ASE argues that CMS’s utilization data does not distinguish clinically necessary imaging from unnecessary volume, ignores the specialized infrastructure, accreditation, staffing, and care coordination that off-campus PBDs provide, and could compound with related PFS-side cuts CMS hasn’t analyzed together. ASE urges CMS to withdraw the proposal, or at minimum exclude echocardiography pending a service-specific evidence review, and separately asks CMS to build a stable, transparent payment pathway for AI-enabled software-as-a-medical-service tools used in cardiovascular imaging.

This letter is directly consequential for echocardiography because CPT 93306, the most commonly billed echo code, is explicitly named as a target of the proposed cut, and a 60% payment reduction in these settings could make it financially unsustainable for hospital-affiliated outpatient departments to continue offering echo services close to patients. ASE’s clinical scenarios (heart failure, cardio-oncology surveillance, endocarditis, post-procedure complications, pediatric Kawasaki disease) show why site-of-service and contrast status are poor proxies for clinical complexity, and the letter reinforces ASE’s consistent advocacy positions favoring accreditation-based quality safeguards over blunt volume or AUC mandates, while also pushing for predictable, additive payment treatment of AI tools rather than allowing them to erode physician reimbursement.