GDS noted in our 11/24/2025 blog that the 2026 OPPS Final Rule finalized CMS’s intent to conduct acquisition cost surveys for specified covered outpatient drugs — laying the groundwork to potentially reinstate lower reimbursement for 340B hospitals.
That survey is now active.
The OPPS Drug Acquisition Cost Survey (ODACS) requires hospitals paid under OPPS and listed on CMS’s ODACS provider table to submit drug acquisition cost data by March 31 at 11:59 p.m. ET.
This is not a routine data request.
The survey results may inform future payment rate reductions for 340B drugs under OPPS. In other words, today’s reporting could influence tomorrow’s reimbursement.
Hospital executives should ensure:
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Whether their organization appears on the ODACS provider list
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Internal coordination between pharmacy, finance, and reimbursement
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Validation of acquisition cost data before submission
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Executive awareness of the downstream payment implications
Failure to comply carries regulatory risk.
For reference:
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OPPSDrugSurvey@cms.hhs.gov for technical questions
