CMS has released the CY 2026 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Final Rule, confirming several major policy shifts while making notable changes to what was originally proposed.
OPPS Highlights
Finalized as Proposed
- Continued phase-out of the Inpatient-Only (IPO) list with a multi-year removal process and related Two-Midnight exemptions. This included the removal of 271 codes from the IPO list.
- Skin substitutes payments restructured and un-packaged as proposed.
- Enhancements to hospital price transparency machine-readable file requirements.
- Expansion of site-neutral payments to drug administration services in excepted off-campus hospital departments.
Changes from the Proposed Rule
- OPPS update increased: Final payment update is +2.6% (up from the proposed +2.4%).
- CMS did not finalize the proposed increase to the 340B budget-neutrality offset (keeping the 0.5% reduction for 2026, rather than increasing it to 2%).
ASC Highlights
Finalized as Proposed
- Major updates to the ASC Covered Procedures List (CPL) following revised safety and clinical criteria. The final rule added 289 procedures under the revised criteria (vs 276 proposed), so the final list is slightly larger than proposed; CMS also added the 271 codes removed from the IPO list as proposed for a total of 560 codes added. A significant portion of the additions are orthopedic procedures.
- Adoption of updates to ASC Quality Reporting (ASCQR) program measures.
- Extension of the hospital market basket update methodology for ASC payments through CY 2026.
- Continued separate payment for approved non-opioid pain management alternatives.
Changes from the Proposed Rule
- ASC payment update increased to +2.6%, mirroring OPPS (vs. the proposed +2.4%).
- CMS added more procedures than originally proposed to the ASC CPL, reflecting broader alignment with the IPO list phase-out and stakeholder input.
Bottom Line:
CMS largely finalized its proposed structural reforms across OPPS and ASC—including site-neutral expansions, transparency enhancements, and modernization of procedure lists—while adjusting payment updates upward and pausing a major proposed 340B offset reduction. These changes will have meaningful implications for outpatient strategy, financial planning, and compliance in 2026.
With implementation barely a month away, outpatient practices should review the final rule in full and begin preparing immediately to ensure their operations, supervision models, and compliance processes are aligned for 2026.
The Final Rule can be found here: 2025-20907.pdf
The CMS Fact Sheet can be accessed here: Calendar Year 2026 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center Final Rule (CMS-1834-FC) | CMS
The separate Fact Sheet for the Hospital Price Transparency Changes is here: CY 2026 OPPS and Ambulatory Surgical Center Final Rule – Hospital Price Transparency Policy Changes | CMS