The Centers for Medicare & Medicaid Services (CMS) on Jan. 1 formally launched the 2026 Outpatient Prospective Payment System (OPPS) Acquisition Cost Survey, urging all OPPS-participating hospitals to take part. Hospitals may submit responses until March 31.
The survey covers 1,843 distinct National Drug Codes (NDCs) and requests that hospitals submit data for every NDC purchased between July 1, 2024, and June 30, 2025.
CMS requests the following data:
- Total Units Purchased – Non-340B
- Total Units Purchased – 340B
- Total Net Acquisition Costs – Non-340B
- Total Net Acquisition Costs – 340B
CMS intends to use the data collected for rulemaking in CY 2027. CMS cannot compel participation in the survey; however, it is still considering how to interpret nonresponses.
An April 17, 2025 executive order on prescription drug prices ordered the Department Health and Human Services (HHS) secretary to develop a plan to conduct a drug acquisition cost survey.
Once the survey is complete, the secretary is ordered to adjust future Medicare payments in a budget neutral manner.
In 2018, following a similar order from President Trump, HHS reduced Medicare outpatient drug reimbursement for 340B hospitals to rates far below non-340B hospital rates.
America’s Essential Hospitals challenged this decision as a plaintiff in AHA v. Becerra and successfully argued to the Supreme Court the policy was illegal. The court ruled explicitly that no adjustments could be made without first conducting a survey.
More information about the survey, including a frequently asked questions page and details on how to submit data, is available on CMS’ website. For technical assistance hospitals may contact the Help Desk via email at SurveyHelpDesk@dcca.com.
Contact Director of Policy Rob Nelb, MPH, at rnelb@essentialhospitals.org or 202.585.0127 with questions.
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