Analyzing the 2026 OPPS and MPFS proposed rules on the July Quarterly Call

Wednesday, July 30, 2025

NAHRI members received association updates and expert insights on the 2026 Outpatient Prospective Payment System (OPPS) and Medicare Physician Fee Schedule (MPFS) proposed rules on the July 2025 NAHRI Quarterly Call.

Association updates

The call opened with NAHRI Director Nicole Votta providing the latest association updates.

The 2025 Revenue Integrity Symposium (RIS) will be held September 25–26, 2025, at the Westin Westminster in Westminster, Colorado. RIS is the premier event for revenue integrity, revenue cycle, and Medicare compliance education and networking. Attendees will learn from trusted experts with cutting-edge insights that will empower them to ensure compliance with regulatory changes, maximize revenue, enhance workflow, and improve program design. Revenue integrity professionals wishing to earn support from program administrators to attend the event can adapt this proposal.

The application period for the 2026 term of the NAHRI Leadership Council is now open. The NAHRI Leadership Council is a unique networking platform that supports revenue integrity leaders and helps them stay on the cutting edge of strategy and thought leadership. Council members have access to an exclusive online community, monthly e-newsletters, and bi-monthly virtual networking calls, as well as many opportunities to collaborate on industry surveys and research initiatives. Submit your application by September 29.

Participating in a NAHRI board or committee is an excellent way to grow your professional network and make a tangible difference in the revenue integrity industry and your career. NAHRI is now accepting applications to the NAHRI Advisory Board and two NAHRI committees: the Networking and Events Committee and the Education Committee. You must be a NAHRI member to serve on the Advisory Board or either committee. The application period is open now through August 4, and the selected applicants will begin their terms on October 1. Click here for more information on the Board, committees, and application process.

Medicare updates, reimbursement changes

A panel of six NAHRI Advisory Board members joined the July Quarterly Call to discuss key provisions in the 2026 OPPS and MPFS proposed rules.

Jugna Shah, MPH, CHRI, founder and CEO of Nimitt Consulting Inc. in Spicer, Minnesota, and John D. Settlemyer, MBA, MHA, CPC, CHRI, associate vice president, revenue cycle, at Atrium Health in Charlotte, North Carolina, kicked off the conversation by highlighting CMS’ call to expand site-neutral payments to include drug administration services furnished at excepted off-campus provider-based departments in the 2026 OPPS proposed rule. The agency is proposing to apply the MPFS rate to any drug administration Healthcare Common Procedure Coding System code reported at excepted off-campus PBDs, citing a need to control “an unnecessary increase in the volume of outpatient services.” Both Shah and Settlemyer said that this rationale may be inadequate, adding that CMS failed to recognize several elements (e.g., patient acuity) that could complicate the shift. Revenue integrity professionals should take time to examine the site neutrality proposals in depth, as CMS is soliciting comments on reducing on-campus clinic visit payments.

Other NAHRI Advisory Board members joined the call to discuss CMS’ proposals to eliminate the inpatient-only list, implement new price transparency requirements, adjust cell and gene therapy payments, and more. Revenue integrity professionals should read the 2026 OPPS and MPFS proposed rules and consider providing feedback to CMS on how the policies could affect their organization and/or job duties. Review NAHRI’s white paper Advocacy in Action: Commenting on Proposed Rules to learn how to craft a meaningful comment. NAHRI will publish additional expert insights on the rules in the upcoming issue of the NAHRI Journal.

A recording of the July Quarterly Call is available for NAHRI members here. Stream more past calls here. Listening to or presenting on Quarterly Calls award one CHRI CEU. Register today for the final Quarterly Call of 2025, which will take place on October 28. If you would like to present on an upcoming call, please contact NAHRI at nahri.@hcpro.com.