OPPS Drug Acquisition Cost Survey deadline extended to April 7
CMS extended the deadline for the Outpatient Prospective Payment System (OPPS) Drug Acquisition Cost Survey (ODACS) to April 7, giving selected hospitals an extra week to submit their data.
The ODACS was established in the 2026 OPPS final rule in response to an April 2025 executive order. Launched on January 1, the survey is designed to collect acquisition costs of certain outpatient drug and biological products purchased by OPPS hospitals. CMS plans to take the survey data into consideration when determining future payment rates and policies, beginning with the 2027 OPPS proposed rule.
CMS used claims data to identify hospitals paid under the OPPS between July 1, 2024, and June 30, 2025, that are to participate in the survey. The agency began reaching out to the selected hospitals in September 2025. To complete the survey, hospitals must register for the online system, upload their drug acquisition cost data using this template, and follow these steps to submit the online attestation form.
CMS initially used language in ODACS guidance indicating that the selected hospitals are required to participate. However, the American Hospital Association and other stakeholders pushed back, noting that the 2026 OPPS final rule states that there is no statutory basis for imposing specific consequences on hospitals that do not respond. CMS revised its ODACS FAQs in response to these comments, but the wording remains vague.
The agency is conducting the ODACS to fulfill a statutory obligation to survey hospitals before reducing reimbursement for certain separately payable drugs. CMS will only meet this burden if the survey produces a “statistically significant estimate” of drug costs. Legal experts have theorized that the deadline extension may indicate that CMS has not yet received enough responses to meet that standard.
Revenue integrity professionals can visit CMS’ ODACS web page for additional resources, including a fact sheet, training webinar, and more.