As we conclude the end of the first quarter subject to the 2016 OPPS Final Rule, hospitals MUST evaluate the new substantive reimbursement requirement (beginning on page 255 of the Federal Register 2016 OPPS Final Rule) recently imposed by CMS. Introduced in the 2015 IPPS Proposed Rule, and later adopted in the 2016 OPPS Final Rule, CMS incorporated into the regulations a concept initially introduced by the PRRB Board Rules in 2008.