SIR summary: Hospital Prospective Payment System Proposed Rule for 2026
On July 15, 2025, the Centers for Medicare and Medicaid Services (CMS) issued the proposed rule for the Hospital Outpatient Prospective Payment System (HOPPS) for calendar year (CY) 2026.
Healthcare policy
Economics
Payment rates
- CMS proposed a 2.4% increase to the outpatient department (OPD) fee schedule for HOPPS and Ambulatory Surgery Centers (ASCs). Based on the market update from the Inpatient Prospective Payment System (IPPS) of 3.2% and a 0.8% productivity adjustment decrease.
- Proposed a conversion factor (CF) of $91.747 for hospitals that meet the Hospital Outpatient Quality Reporting (OQR) requirements and applies the 2% reduction to those that do not, with a CF equal to $89.958.
- Under the 340B Final Remedy Rule, CMS proposed to impose an annual 2% reduction to HOPPS CF beginning in CY 2026 for non-drug items and services for hospitals in which this adjustment applies. The proposed CF for these hospitals is $89.958. Ambulatory Surgery Centers (ASCs) are not impacted by the 2% reduction for the 340B offset remedy.
- CMS estimates total payments to HOPPS providers will be approximately $100.0 billion, which is an increase of roughly $8.1 billion compared to CY 2025 HOPPS payments.
- Cancer hospital payment-to-cost ratio (PCR) proposed for CY 2026 at 0.87 for the 11 designated hospitals.
Ambulatory payment classifications (APCs)
- CMS proposed to continue to pay for all multiple imaging procedures within an imaging family performed on the same date of service using the multiple imaging composite APC payment methodology.
- Standard APC assignments will continue to apply for single imaging procedures and multiple imaging procedures performed across imaging families. A single imaging session performed “with contrast” is part of a composite APC when at least one or more imaging procedures from the same family are also performed with contrast on the same date of service. For example, if a hospital performs one MRI without contrast during the same session as one with contrast, the payment rate will be for the “with contrast” composite APC.
- CMS proposes to assign several new technologies to new APCs for CY 2025.
- Proposed for services to new technology APCs based on requestor applications
- LimFlow TADV procedure CPT Code 0620T (APC 1579)
- Liver Histotripsy Service CPT Code 0686T (APC 1579)
Eliminating the inpatient only list
- CMS proposed to phase out the inpatient only (IPO) list over a 3-year period, beginning with the removal of 285 mostly musculoskeletal procedures for CY 2026 and completing the changes by Jan. 1, 2029.
- For interventional radiology this includes the proposed removal of CPT codes 37182 (Insertion of transvenous intrahepatic portosystemic shunt(s) [TIPS] [includes venous access, hepatic and portal vein catheterization, portography with hemodynamic evaluation, intrahepatic tract formation/dilatation, stent placement and all associated imaging guidance and documentation]) and 61624 (Transcatheter permanent occlusion or embolization [e.g., for tumor destruction, to achieve hemostasis, to occlude a vascular malformation], percutaneous, any method; central nervous system [intracranial, spinal cord]) from the IPO only list effective Jan. 1, 2026.
- For interventional radiology this includes the proposed removal of CPT codes 37182 (Insertion of transvenous intrahepatic portosystemic shunt(s) [TIPS] [includes venous access, hepatic and portal vein catheterization, portography with hemodynamic evaluation, intrahepatic tract formation/dilatation, stent placement and all associated imaging guidance and documentation]) and 61624 (Transcatheter permanent occlusion or embolization [e.g., for tumor destruction, to achieve hemostasis, to occlude a vascular malformation], percutaneous, any method; central nervous system [intracranial, spinal cord]) from the IPO only list effective Jan. 1, 2026.
Diagnostic radiopharmaceuticals
- CMS proposed a per-day cost threshold of $655 for qualifying nonpass-through, separately payable diagnostic radiopharmaceuticals.
Applications for device pass-through status
- Approved application for device pass-through payment during the quarterly review process for VasQ, a nitinol implant which is surgically placed outside and/or around an artery and/or vein to provide external support to arteriovenous fistulas created for vascular access by means of vascular surgery.