CMS is proposing significant changes to how outpatient drugs, procedures, and new technologies are reimbursed. We examine the provisions with the greatest commercial impact.
The Calendar Year (CY) 2027 Outpatient Prospective Payment System (OPPS) and Ambulatory Surgical Center (ASC) proposed rule is less about the headline payment update and more about how the Centers for Medicare and Medicaid Services (CMS) continues to reshape outpatient economics. While the proposed 2.4% payment update offers modest relief, the more meaningful changes focus on site-of-care incentives, drug payment methodology, and the reimbursement pathways supporting new technologies.
For manufacturers and providers alike, the proposal reinforces a broader trend: Medicare is increasingly rewarding efficient sites of care while applying greater scrutiny to products and procedures that drive outpatient spending.
The rate update is only part of the story
The proposed 2.4% update for both OPPS and ASC payment systems is important but unlikely to change strategic priorities on its own. Instead, organizations should focus on policy changes that influence reimbursement across drugs, devices, procedures, and sites of care.
Drug payment policy continues to evolve
The most consequential drug proposal is CMS’s plan to pay for 340B-acquired drugs at average sales price (ASP) minus 33.4% beginning in CY 2027. The proposed rate is based on the Medicare OPPS Drug Acquisition Cost Survey, which collected hospital acquisition cost data for separately payable outpatient drugs between January and April 2026. While CMS would continue to pay non-340B drugs generally at ASP plus 6%, the proposal represents a broader shift toward using hospital acquisition-cost data to inform outpatient drug reimbursement.
CMS also proposes to accelerate the 340B remedy offset by increasing the annual reduction to non-drug OPPS payment amounts from 0.5% to 3% for affected hospitals. Together, these proposals would create meaningful variation in provider economics depending on 340B participation, service mix, and procedural volume.
Radiopharmaceutical policy is less dramatic, but still important. CMS proposes to continue its diagnostic radiopharmaceutical payment framework, with a modest increase in the diagnostic radiopharmaceutical packaging threshold to $665 for CY 2027. CMS also continues to encourage ASP reporting for diagnostic radiopharmaceuticals, signaling that the agency could eventually transition from claims-based mean unit cost (MUC) to an ASP-based payment methodology once sufficient reporting is available.
Site-of-care pressure keeps building
CMS proposes expanding site-neutral payment by reimbursing certain imaging without contrast services performed in excepted off-campus provider-based departments at the Physician Fee Schedule equivalent rate. The proposal extends CMS’s incremental expansion of site-neutral payment policies and reinforces the agency’s continued effort to reduce payment differentials across care settings and encourage care in lower-cost outpatient sites of care when clinically appropriate.
Procedures move to outpatient settings
As part of CMS's three-year strategy to phase out the Inpatient Only (IPO) list, the agency proposes removing more than 600 procedures from the IPO list while adding 618 procedures to the ASC Covered Procedures List. At the same time, CMS proposes lowering the ASC weight scalar and requests feedback on whether the device portion of device-intensive procedures should also be scaled in future years. Given the continued shift toward ASCs and their already compressed willingness–to–pay, scaling device reimbursement in this setting can become an issue with potentially meaningful commercialization and pricing implications for device manufacturers.
Temporary payment pathways are changing
CMS proposes eliminating the Breakthrough Device alternative pathway for OPPS device pass-through applications, potentially increasing the importance of early reimbursement strategy and evidence generation for manufacturers of novel technologies. At the same time, CMS would continue separate payment for qualifying non-opioid pain relief products through CY 2027.
Where stakeholders should engage
The proposed rule includes several Requests for Information (RFIs) and comment opportunities that could shape future outpatient payment policy. Stakeholders should consider engaging where proposals have the potential to influence reimbursement, market access, and commercialization strategy, including:
- 340B acquisition cost survey methodology and implementation of ASP minus 33.4% payment;
- Future reimbursement pathways for emerging technologies, including elimination of the Breakthrough Device alternative pathway for OPPS device pass-through payment;
- Potential scaling of the device offset for device-intensive procedures in ASCs;
- ASP reporting for diagnostic radiopharmaceuticals and future payment methodology;
- RFI for Hospital Price Transparency, including standardization of machine-readable files and reporting of complex contracting methodologies; and
- RFI on potential future IPPS payment approaches for domestically manufactured PPE and essential medicines.
Looking ahead
The CY 2027 proposed rule signals that CMS is using payment policy to influence where care is delivered, how providers are reimbursed, and how new technologies enter the outpatient market. Organizations that evaluate these proposals through a reimbursement, pricing, market access, and commercial lens will be in a stronger position to respond as the outpatient landscape continues to evolve.
The window to influence is short, and stakeholders wishing to engage should act promptly. Comments are due by August 31, 2026.
How Simon-Kucher can help
We invite you to connect with us to map the relevant reimbursement policy stack to your product and channel strategy, stress-test your launch plans, and quantify cross-program exposure through scenario modeling. This can help your organization move from regulatory policy fluency to precision-driven actions at launch or in-market.
