Article
What hospitals told CMS
The American Hospital Association filed comments on Aug. 28 on the proposed 2027 outpatient and ambulatory surgical center payment rule. Its central complaint is the proposed 2.4% net update, which reflects a 0.8 percentage point productivity reduction. The group asked CMS to work with Congress to shrink that reduction for 2027 or remove it altogether, arguing that the update does not match the cost pressures hospitals face.
The proposals with the most budget impact
- Imaging at off-campus departments. CMS would lower payment for imaging without contrast at excepted off-campus provider-based departments. The AHA opposes the cut and wants it withdrawn. Systems with large hospital-based imaging networks off the main campus should quantify their exposure now.
- Inpatient-only list. This is the second year of CMS’s plan to phase out the list. The AHA asked the agency to return to the case-by-case removal process it used in 2025. As more procedures move to outpatient status, payment per case and site-of-care decisions shift.
- Surgical center list. CMS wants to add more procedures that can be paid in ambulatory surgical centers. The AHA raised safety concerns and urged the agency to drop the expansion. For hospital finance teams, the issue is volume leaving outpatient departments for lower-paid settings.
- Prior authorization. CMS would extend outpatient prior authorization to more botulinum toxin injection codes. The AHA says these services are mostly medical rather than cosmetic and should not face added review.
- Separate identifiers. Hospitals must obtain a separate national provider identifier for each off-campus department, and the AHA asked CMS to ease the burden of doing so.
How to plan before the final rule
Final outpatient rules usually arrive in November, which leaves little time before budgets close. Finance leaders should build a base case at the proposed update and test the imaging and surgical center provisions separately, so each can be dropped or kept as the final rule dictates.
Strategy teams should also review where outpatient imaging and surgery sit today. If site-neutral policy keeps expanding, the economics of off-campus hospital departments versus freestanding or joint venture models will keep changing. Revenue cycle leaders should prepare for the separate identifier requirement and any new prior authorization codes so claims are not delayed early next year.
Archive entry for Sep 3, 2026, added Nov. 11, 2026.