Article
What CMS finalized
The calendar year 2027 hospital outpatient and ambulatory surgical center rule, released Nov. 4, takes effect Jan. 1. Hospitals that meet quality reporting requirements receive a net 2.3% update: a 3.2% market basket increase less a 0.9 percentage point productivity adjustment.
The headline is 340B. Separately payable drugs acquired through the program will be paid at average sales price minus 28%, rather than the minus 33.4% CMS proposed in July. The rate is now built from HRSA ceiling price data instead of the agency’s acquisition cost survey. Because the change is budget neutral, payment for non-drug items and services rises 7.5%. Rural sole community hospitals, children’s hospitals and PPS-exempt cancer hospitals are exempt, and hospitals outside 340B keep ASP plus 6%.
The clawback is the bigger number
To recoup an estimated $7.8 billion tied to its earlier 340B payment remedy, CMS will reduce the outpatient conversion factor by 2% a year, up from 0.5%. That is less than the 3% CMS floated, and because it applies to the conversion factor itself, it reaches every hospital paid under the OPPS. CMS expects the recoupment to finish by 2031.
Site-neutral payment also widens. Imaging without contrast furnished in grandfathered off-campus departments will be paid at 40% of the OPPS rate, an estimated $260 million reduction in 2027, with rural sole community hospitals exempt. Separately, CMS removes 637 more services from the inpatient-only list, and starting in 2028 each off-campus department will need its own NPI and provider-based attestation.
What leaders should do this quarter
- Model the net effect by site. For a 340B hospital, the drug cut, the 7.5% lift on services and the 2% conversion factor reduction pull in different directions. Run them together, by department, rather than reading the 2.3% headline.
- Re-price off-campus imaging. Identify which grandfathered locations bill non-contrast imaging and test whether volume, staffing or ownership structure still makes sense at the lower rate.
- Prepare for case migration. As more procedures leave the inpatient-only list, expect payers and surgeons to push cases to outpatient and ASC settings. Align capacity and physician partnership plans accordingly.
- Start the 2028 enrollment work now. Separate NPIs and attestations for each off-campus site will take credentialing, IT and revenue cycle time.