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2026 Prospectus

November 2025 in review: Shutdown ends, OPPS final rule squeezes outpatient

November 2025 in review: Shutdown ends, OPPS final rule squeezes outpatient
Greg Wahlstrom, MBA, HCM

Congress reopened the government and restored virtual care authority through January, while CMS finalized an outpatient rule that expands site-neutral payment and begins retiring the inpatient-only list.

November brought relief on one front and new pressure on another. The longest federal shutdown on record ended, temporarily restoring programs hospitals had been operating at risk, and CMS finalized an outpatient payment rule that moves several long-debated policies forward.

Shutdown ends with a short runway

The President signed a funding bill on November 12, ending a shutdown that began October 1. A continuing resolution funds most of the government through January 30, 2026. Medicare telehealth flexibilities and the Acute Hospital Care at Home program were extended to the same date, with retroactive payment for telehealth services delivered during the lapse.

The bill did not extend the enhanced ACA premium tax credits. Senate Majority Leader John Thune instead committed to a floor vote by mid-December. Leaders now face two near-term deadlines: year-end for the subsidies and January 30 for government funding and the virtual care extensions.

2026 OPPS: modest update, broader site neutrality

CMS released the calendar 2026 outpatient final rule on November 21. Key provisions:

  • Payment update: a net 2.6% increase, reflecting a 3.3% market basket less a 0.7-point productivity adjustment.
  • Site-neutral drug administration: grandfathered off-campus provider-based departments will be paid at 40% of the OPPS rate for drug administration, an estimated $290 million reduction. Rural sole community hospitals are exempt.
  • Inpatient-only list: a three-year phase-out begins, alongside 547 procedures added to the ASC covered list.
  • 340B remedy offset: the 0.5% annual reduction to non-drug payments continues in 2026 rather than accelerating, though CMS signaled hospitals should expect larger reductions, up to 2%, beginning in 2027.
  • Price transparency: updated requirements take effect January 1, with enforcement starting April 1.

AHA said the rule adds to the financial strain hospitals already face. The combination of site-neutral expansion and IPO phase-out will push more volume toward ambulatory settings, which favors systems that own or partner with ASCs.

Every state applies for rural transformation funds

CMS reported on November 5 that all 50 states had applied for the $50 billion Rural Health Transformation Program. Awards are due by December 31. Rural hospitals should confirm how their state’s application treats provider sustainability and workforce, since those choices will shape where dollars land.

Executive takeaway: Model the OPPS changes at the service-line level, especially off-campus drug administration, and plan for a possible second funding cliff on January 30.

Sources

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