The ACC submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) on Sept. 4, providing feedback and raising concerns on several issues of relevance to the cardiovascular community in the 2025 Hospital Outpatient Prospective Payment System (OPPS) proposed rule. 

Highlights from the College’s comments include: 

• Urging CMS to add cardiac catheter ablation procedures to the Covered Procedures List after several years of submitted requests have gone unaddressed in proposed rules. 
• Requesting complexity adjustment analysis for coronary intravascular lithotripsy to continue sufficient reimbursement as the new technology diffuses through the system.  
• Tentatively supporting a CMS proposal to pay separately for diagnostic radiopharmaceuticals with a per-day cost greater than $630.  
• Urging modifications of cardiac imaging services including PET, CT and MRI to higher, more appropriate ambulatory payment classifications.   
• Recommending continuation of direct supervision for cardiac rehabilitation and pulmonary rehabilitation being allowed via telecommunication technology and supporting the currently proposed one-year extension through 2025.  
• Supporting CMS’ proposal to decrease mandatory response time for standard prior authorization requests from 10 business days to seven calendar days and expedited decisions from 72 hours to two business days.  

You can read the ACC’s full comment letter here. For more information on the 2025 OPPS proposed rule, access the full text or the accompanying press release and fact sheet. CMS will consider comments and post the final rule around Nov. 1, which is set to take effect on Jan. 1, 2025.

Explore the ACC’s Regulatory Affairs Roadmap for more on how the College responds to regulatory rulings and advocates on behalf of its members.

Keywords: ACC Advocacy, Centers for Medicare and Medicaid Services, U.S., Outpatients, Feedback, Prospective Payment System