2026 OPPS final rule: Hospitals facing expanded site neutrality policies, new price transparency requirements
CMS moved ahead with significant expansions to its site neutral payment policies, including reductions to payments for certain services at expected off-campus provider based departments (PBD), additional price transparency requirements, changes to its methodology for setting MS-DRG rates, and more, according to the 2026 Outpatient Prospective Payment System (OPPS) final rule.
CMS finalized a 2.6% increase to OPPS payments for 2026.
CMS finalized its proposal to expand its site neutral payment policy to include drug administration services furnished at excepted off-campus PBDs. For 2026, the agency will apply the Medicare Physician Fee Schedule (MPFS) rate to any drug administration Healthcare Common Procedure Coding System (HCPCS) reported at excepted off-campus PBDs.
In another move toward site neutrality, CMS will begin to phase out the inpatient-only list starting in 2026. The list will be phased out over three years. Procedures removed from the inpatient-only list will be exempt from medical review audits related to the 2-midnight policy. The exemption policy would be in effect until CMS determines that the procedure is more commonly performed in the outpatient setting among Medicare beneficiaries.
CMS finalized its proposal to unpackage skin substitute products when paid under the OPPS and establish Ambulatory Payment Classifications (APC) based on product characteristics. Similarly to the 2026 MPFS final rule, the agency will align skin substitute categorization with the product’s FDA regulatory status. For 2026, CMS will use a single payment rate based on the highest average for the three FDA categories of skin substitute products. Different payments may be created for the three categories in future rulemaking. These policy changes apply to both physician office settings and hospital outpatient departments.
CMS is moving ahead with its proposal to median payer-specific negotiated charges, as reported on the Medicare cost report, to calculate MS-DRG relative weights beginning in fiscal year 2029.
CMS made some modifications to its proposals for hospital price transparency policies, but generally finalized them. Starting January 1, 2026, hospitals must disclose the tenth, median and ninetieth percentile allowed amounts in their machine-readable files (MRF) when payer-specific negotiated charges are based on percentages or algorithms. Hospitals would also be required to include the count of allowed amounts used to determine the percentiles. CMS also made changes to attestation requirements and additional technical requirements.
The final rule details numerous other changes that will have meaningful impacts on hospitals operations and revenue. Revenue integrity professionals should read the final rule carefully, making note of all provisions that will directly affect their organization, job duties, and community. Meet with colleagues in other departments to discuss education plans, systems updates, and other tasks that will have an interdepartmental effect.