CMS has issued a proposed rule that would raise payment rates for hospital outpatient departments and ambulatory surgery centers while continuing to close the payment gap between sites of care. LauraLee Lawley of Parker Poe Adams & Bernstein LLP breaks down what the rule means for hospitals, ASCs, and outpatient investors.
The rule would increase OPPS and ASC payment rates by 2.4% for calendar year 2027 and remove more than 600 procedures from the inpatient-only list, potentially expanding what can be performed in outpatient settings. It would also reduce payment differences for certain imaging services at off-campus hospital outpatient departments compared to physician offices, revise the payment methodology for 340B-acquired drugs, and expand prior authorization requirements for select outpatient services. The rule is open for public comment through August 31, 2026, and would take effect in 2027.
Key takeaways for health systems, ASC operators, and investors:
• Removal from the inpatient-only list does not equal automatic readiness. Facilities must still assess clinical, staffing, equipment, and licensure requirements
• Off-campus hospital outpatient departments should evaluate reimbursement exposure tied to proposed imaging payment cuts
• Hospitals in the 340B program should model the financial impact of the proposed drug payment methodology change
• Expanded prior authorization requirements could affect scheduling, documentation, and revenue-cycle workflows
• Investors and operators should factor site-neutral trends into ASC acquisitions, joint ventures, and outpatient service-line valuations
Buyers, sellers, lenders, and joint venture partners evaluating outpatient transactions should confirm target facilities have the clinical capabilities, licensure, and compliance infrastructure to support anticipated procedure expansion and should ensure agreements adequately allocate risk for payment and compliance changes.
Read the full analysis here: