What revenue leaders should be doing right now
The CY 2026 OPPS & ASC Final Rule (CMS-1834-FC) that went into effect on January 1, 2026, includes several payment and policy shifts that revenue cycle teams should be operationalizing now – especially those that affect site of care, payment methodology, 340B recoupment, drug reporting, skin substitutes and hospital price transparency.
Policy changes drive real impact
CMS finalized a 2.6% net market basket increase for hospital outpatient departments (HOPDs) and ambulatory surgery centers (ASCs) that meet applicable quality reporting requirements. Revenue cycle teams should view this as their baseline and focus on policy changes that could shift volumes and margins across departments and settings.
Site neutrality drug administration paid at 40%
CMS finalized a site-neutral payment reduction for drug administration services furnished in grandfathered off-campus provider-based departments (PBDs). This is particularly important for infusion-heavy operations. Even small configuration errors like department mapping, billing edits and place-of-service logic can quickly become outsized payment and compliance issues.
Inpatient not required but may still be appropriate
The decision to phase out the IPO list over three years increases the need for clear admission status governance, consistent medical necessity documentation and proactive denial prevention. Leaders need to ensure clinicians are aware of how to properly document an inpatient admission where appropriate and that the organization can operationally support an expanded outpatient footprint.
ASC covered procedures list expands
CMS removed five regulatory exclusion criteria and added 560 surgical procedures and 35 ancillary services to the ASC covered procedures list (CPL). For RCM leaders, the takeaway is that more volume can and will shift to ASCs, which affects front-end authorization workflows, payer terms, estimating and downstream charge capture.
To review the full list of 2026 OPPS & ASC final rule highlights and insights, download our regulatory brief.
2026 OPPS & ASC operational checklist
RCM Operations & Patient Access
- Reassess pre-service workflows for procedures affected by the IPO phase-out and the expanded ASC CPL such as scheduling rules, medical necessity prompts and front-end claim accuracy.
- Validate authorization pathways and financial clearance steps as more cases shift to outpatient/ASC settings.
Revenue Integrity & Charge Capture
- Confirm charging workflows and edit logic for drug administration services furnished in grandfathered off-campus PBDs, including correct department mapping and claim routing.
- Review outpatient charging controls for supply-intensive services likely impacted by site-of-service shifts.
HIM & Coding
- Prepare coding guidance and internal education for changes affecting skin substitutes, including code deletions and new payment treatment as supplies.
- Ensure documentation and coding alignment supports correct inpatient vs outpatient classification as IPO removals begin.
Payer Contracting & Managed Care
- Identify procedures likely to migrate to ASCs and evaluate whether current payer terms support the organization’s intended site-of-care strategy.
- Coordinate with RCM and service line leadership on any needed payer engagement including coverage policies, prior authorization expectations and reimbursement parity considerations.
Pharmacy Finance & Reimbursement
- Establish governance and data capture readiness for the OPPS drug acquisition cost survey beginning January 2026.
- Reconcile policy changes affecting separately payable drugs with internal charge capture and billing practices.
Compliance & Price Transparency Team
- Update machine-readable file production processes to support percentile allowed amounts, 835-based data, NPI encoding and by responsible executive.
- Complete a gap assessment and remediation plan well before April 1, 2026,
Finance & Decision Support
- Incorporate the 6% update, site-neutral payment reduction, and -0.5% 340B recoupment reduction into 2026 budgeting and service line modeling.
- Align financial assumptions with operational plans for outpatient migration and ASC utilization.
