2026 Medicare Payment Proposals: A Pivotal Moment for ASCs
Marta Beile, Compliance Manager at nimble solutions.
When CMS dropped its nearly 1,000-page 2026 proposed Medicare payment rule for ASCs and hospital outpatient departments (HOPDs) in July, one thing became clear:
We’re looking at one of the biggest potential site-of-service shifts in years.
If finalized, this rule would bring a three-year phase-out of the Inpatient-Only (IPO) list, add 547 new procedures to the ASC Covered Procedures List (ASC-CPL), streamline ASC quality reporting, and deliver a modest 2.4% payment rate increase (CMS, July 15, 2025; ASCA, July 16, 2025).
This combination could accelerate the migration of higher-acuity cases—spine, orthopedics, cardiovascular—into the ASC setting. And while the opportunities are big, they also come with operational and financial realities that require planning now, not later.
1. IPO phase-out + 547 new ASC-eligible procedures
CMS plans to retire the IPO list over three years, starting in 2026 with hundreds of musculoskeletal cases. This shift would move 271 procedures from the IPO list into the ASC-CPL and add another 276 brand-new procedures—547 total.
Notable additions include:
- Spine: Posterior lumbar fusions (22630)
- Cardiovascular: PCI (C9602)
- GI: POEM for achalasia (43497)
“The proposed expansion… reflects our longstanding belief that the clinical judgment of the medical community is the proper determinant for where patients can receive their care.” — Bill Prentice, ASCA CEO
Bottom line: higher-acuity, higher-revenue cases could soon be on the table for ASCs.
2. Quality reporting that’s more meaningful
CMS is proposing to drop several high-burden measures and introduce a patient-reported outcome measure on post-procedure recovery understanding. The shift is toward metrics that reflect patient priorities, not just compliance checkboxes.
3. Payment rate update
ASCs and HOPDs would both see a 2.4% increase—based on a 3.2% hospital market basket minus a 0.8% ACA productivity adjustment. While modest, it’s aligned with HOPD updates and still meaningful in an environment of rising costs and payer pressure.
The upside—and the watchouts
Opportunities for ASCs
- More services in a cost-effective, high-quality setting
- A broader scope to attract new physician partners
- Quality reporting that better reflects patient priorities
- Revenue potential: higher-acuity cases often bring higher reimbursement—if coding, documentation, and payer strategies are ready
Potential challenges
- Commercial payer negotiations could get more complex
- Hospital opposition in certain markets
- Operational readiness for higher-acuity workflows
- Revenue cycle alignment to avoid denials and delays
Why the planning window is now
The comment period closes September 16, with final rules expected in November—leaving just weeks before January 1, 2026. That’s a short runway to:
- Analyze which new codes make sense financially
- Update payer strategies to protect rates
- Prepare workflows for the new PRO measure
- Engage surgeons early to align on case mix and scheduling
Positioning for what’s ahead
Changes of this scale don’t just affect the OR schedule—they influence payer strategy, documentation standards, and the ability to turn cases into clean claims and timely reimbursement.
The ASCs that will make the most of these shifts are the ones already thinking through the financial, operational, and clinical implications—and building the right infrastructure now to handle more complex cases with confidence.
At nimble, we’re already mapping these proposed changes against our clients’ service lines, payer contracts, and operational capacity—so when January 1 arrives, you’re not scrambling to catch up.
At nimble, we’re proactively aligning these proposed changes with our clients’ service lines, payer contracts, and operational capacity—so they can move into January 1 prepared and confident. Reach out to our team if you’d like to discuss how this may impact your ASC.