Bridge Oncology Regulatory Update
CMS Releases the CY 2027 OPPS & ASC Proposed Rule: What Hospital Leaders Need to Know
The Centers for Medicare & Medicaid Services (CMS) has released the CY 2027 Hospital Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) Proposed Rule (CMS-1850-P). While radiation oncology saw encouraging reimbursement updates, the broader proposal signals much larger changes that will impact nearly every hospital service line.
The proposed rule continues CMS’ long-term strategy of shifting care to lower-cost settings, increasing payment transparency, strengthening program integrity, and reducing Medicare expenditures through expanded site-neutral payment policies. For hospital executives, oncology leaders, pharmacy departments, finance teams, and compliance professionals, now is the time to begin evaluating the operational and financial implications before the rule is finalized.
A 2.4% Payment Update—But Margin Pressures Remain
CMS proposes a 2.4% increase in OPPS and ASC payment rates for organizations that successfully meet Hospital Outpatient Quality Reporting (OQR) requirements. Facilities that fail to meet quality reporting standards would receive a 2% reduction in reimbursement.
Although any payment increase is welcome, most organizations continue to experience inflationary pressures that significantly outpace Medicare reimbursement growth. Rising labor costs, drug acquisition expenses, capital investments, and technology costs continue to challenge hospital operating margins, making operational efficiency more important than ever.
CMS Continues the Migration to Outpatient Care
One of the largest operational changes proposed is the continued movement of services away from inpatient care.
CMS proposes removing 637 procedures from the Inpatient Only (IPO) List, allowing many additional procedures to be safely performed in the hospital outpatient setting. Simultaneously, the agency proposes adding 618 procedures to the ASC Covered Procedures List, further expanding opportunities for ambulatory surgery centers.
Hospitals should begin evaluating physician alignment, outpatient capacity, scheduling models, staffing plans, and ASC partnerships. Organizations that proactively redesign care delivery will be better positioned to capture outpatient volume while maintaining financial sustainability.
340B Takes Center Stage
Although radiation oncology experienced favorable reimbursement changes, the biggest financial story in this proposed rule is undoubtedly the future of the 340B Drug Pricing Program.
CMS proposes reducing reimbursement for separately payable 340B-acquired drugs to Average Sales Price (ASP) minus 33.4%. This represents one of the most significant proposed reimbursement reductions the program has faced.
To maintain budget neutrality, CMS proposes increasing non-drug OPPS payments by approximately 8.44%.
The financial impact will vary considerably depending on each organization’s service line mix. Hospitals with large oncology infusion programs, specialty pharmacy services, and high-cost drug utilization should begin modeling these changes immediately. Understanding how the proposed payment reductions affect department margins, contribution margins, and overall Total Cost of Care will be critical throughout the remainder of the rulemaking process.
Support Continues for Advanced Oncology Imaging
CMS proposes continuing separate payment for qualifying high-cost diagnostic radiopharmaceuticals that exceed established packaging thresholds.
This policy supports hospitals investing in advanced PET imaging, molecular imaging, nuclear medicine, and theranostic programs by recognizing that many of these diagnostic agents carry acquisition costs well beyond traditional packaged payment methodologies.
As precision oncology continues to expand, maintaining reimbursement for these advanced diagnostics remains essential to patient access.
Continued Support for Non-Opioid Pain Management
CMS also proposes continuing separate Medicare payment for qualifying non-opioid pain management therapies provided in both hospital outpatient departments and ambulatory surgery centers.
This policy continues CMS’ efforts to improve patient access to alternatives that may reduce opioid exposure following surgical procedures while supporting multimodal pain management strategies.
Prior Authorization Expansion Continues
The proposed rule expands Medicare prior authorization requirements to include Botulinum Toxin injections.
While relatively limited in scope today, this proposal reflects CMS’ broader strategy of expanding utilization management tools across additional services. Healthcare organizations should anticipate continued growth in prior authorization requirements in future payment rules and continue investing in efficient authorization workflows.
Site-Neutral Payment Remains a Top CMS Priority
Perhaps the most important long-term policy trend within this proposed rule is CMS’ continued expansion of site-neutral payment policies.
Additional imaging services, including certain non-contrast imaging procedures, are proposed for site-neutral reimbursement as CMS continues narrowing payment differences between hospital outpatient departments and physician office settings.
This initiative has implications far beyond imaging. It represents a continued shift toward paying for services based on clinical complexity rather than location of care.
For oncology service lines, this reinforces the importance of understanding true departmental costs, maximizing operational efficiency, and preparing for continued reimbursement pressure in future rulemaking cycles.
Additional Highlights
Other notable proposals include:
- Continued implementation of the 2026 payment methodology for skin substitute products.
- New EMTALA accreditation survey requirements and updates affecting emergency care compliance.
- Refinements to Hospital Outpatient Quality Reporting measures, including removal of the Follow-Up Colonoscopy documentation measure.
- A Request for Information (RFI) seeking stakeholder input regarding future Hospital Price Transparency reporting requirements.
- Updates related to provider-based departments and implementation of provisions included in the Consolidated Appropriations Act of 2026.
Bridge Oncology Perspective
The CY 2027 OPPS Proposed Rule reinforces a trend we have been discussing with our clients throughout the past year: reimbursement alone will no longer determine financial success.
Healthcare organizations must increasingly understand the relationship between reimbursement, operational workflows, utilization patterns, staffing models, and Total Cost of Care. The organizations that thrive in 2027 will be those that move beyond simply reacting to payment changes and instead use data to proactively redesign how care is delivered.
At Bridge Oncology, we are already helping clients model the financial implications of the proposed rule, evaluate 340B exposure, assess radiation oncology and infusion profitability, analyze utilization trends, optimize operational workflows, and prepare for the next generation of value-based reimbursement.
As additional details are released—including the CY 2027 Medicare Physician Fee Schedule (MPFS) Proposed Rule—we will continue providing timely analysis and practical guidance to help our clients navigate an increasingly complex reimbursement landscape.